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14 Cards in this Set
- Front
- Back
- 3rd side (hint)
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Circular 230
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Rules governing the authority to practice before the IRS
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Practicing Before the IRS if...
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taxpayer rights 2. Represents taxpayer at conference or meeting between the IRS 3. Prepares documents to file before the IRS 4. Renders written advice having a potential for tax avoidance or evasion |
4 scenarios
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NOT practicing before the IRS
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2. providing information upon request of the IRS 3. appearing as a witness for a person |
3 scenarios |
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Persons authorized to practice to practice before the IRS
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2. CPAs 3. Enrolled Agents |
3 groups of people |
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Representation before the IRS w/out enrollment
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2. Employee- Regular full-time employee 3. Practitioner 4. Others- if authorized by the IRS |
4 scenarios
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Practitioner |
Anyone authorized to practice before the IRS |
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Conflict of Interest
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Criteria that must be met in order to represent conflicting interests (2) |
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Diligence |
A. Presumed if... 1. Relied upon the work product of another person 2. Uses reasonable care B. Cannot reasonably delay matters before the IRS |
3 criteria
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Endorsement of IT refund check
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negotiate or endorse a check |
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Return of Client's Records
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client's records upon request, regardless of a fee dispute |
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Return of Client's Records- exceptions |
-Returns or other documents PREPARED by the practitioner can be withheld over a fee dispute |
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Tax position is UNREASONABLE unless...
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or 2. the position was properly disclosed & had reasonable basis |
2 criteria |
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Reasonable grounds for omitting an answer |
insignificant to taxable income or tax liability 2. Uncertainty exists about the meaning of the question 3. Answer to the question is extensive |
3 scenarios
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When are use of estimates are permitted?
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It is impracticable to obtain exact data |
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