Use RIA Checkpoint to answer the following questions.

1. A client of your firm, Lenny, filed a fraudulent return in 2015, omitting $200,000 of income. In May, 2018, his conscience got the better of him and he filed a correct amended return reporting the $200,000 but did not pay the related tax due. In 2023, the IRS sent Lenny a notice of deficiency demanding Lenny pay taxes, interest, and penalties on the $200,000. Lenny believes the IRS cannot collect anything from him because the statute of limitations on the return filed in 2018 has expired. One of your tax partners asks you to find a pertinent case with the following citation: 464 US 386. Is Lenny correct, and which Justice wrote the opinion?

a. No, OConnor.

b. Yes, Powell.

c. No, , Blackmun.

d. Yes, Burger.

2. While researching a tax question for a client you locate a case with the following citation: TC Memo 1992-170. You believe this case will be very helpful to your clients position, however, you want to determine whether any other courts have cited the case favorably. How many courts have cited the case favorably?

a. 21.

b. Zero.

c. 2.

d. None of the above.