1. Compute a late-filing and late-payment penalty for a delinquent income tax return.
2. Describe the normal statute of limitations for a tax return and explain the circumstances that extend the statute.
3. Identify the three types of IRS audits.
4. Describe the circumstances in which the IRS imposes a negligence or a civil fraud penalty.
5. Compare the consequences of civil fraud and criminal fraud.
6. Contrast the operations of the three federal trial courts that hear tax cases.
7. Explain the role of the U.S. Circuit Courts and the Supreme Court in the tax litigation process.
8. Define the term transferee liability.
9. Explain the purpose of the innocent spouse rule.