REGLesson 3 of 3

Tax Research & IRS Procedures

Concept

Authority Hierarchy

Primary: IRC, Treasury Regulations, Tax Treaties. Secondary: Revenue Rulings, PLRs, TAMs. Courts: Supreme Court, Circuit Courts, Tax Court, District Courts.
Key Point

Statute of Limitations

3 years from filing. 6 years if >25% gross income omitted. Unlimited for fraud or non-filing.
Concept

Penalties

Accuracy: 20% of underpayment. Fraud: 75%. Failure to file: 5%/month up to 25%. Failure to pay: 0.5%/month up to 25%.
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Practice questions from this module to reinforce what you learned.
Practice Questions