P3-U11 · PART 3 · SOURCE CYCLE 2026-2027
IRS Appeals and U.S. Tax Court
How to complete this unit
This unit uses 18 source-gated recall cards and 18 admissible practice questions. Complete the sequence in order; the unreleased wiki prose remains outside the learner path.
- 1 · LearnBuild the rule
Answer each recall prompt before opening it. Then learn the exact rule, test the controlling facts through four quick challenges, explore common questions, and finish with one own-words teach-back.
- 2 · ApplyUse it in context
Complete at least 18 mapped questions over two sessions. Review the explanation even when the answer is correct.
- 3 · ProveTest readiness
Use the Part 3 mock under time pressure. Return here for every flagged or missed concept before the next attempt.
Verified recall questions
Only cards whose complete question and answer were checked against exact primary-authority evidence appear here. Stable unit ownership gathers this lesson across 1 textbook collection.
Q1.When may the burden of proof shift to IRS under section 7491?
taxpayer introduces credible evidence on a factual issue taxpayer satisfies substantiation and recordkeeping requirements taxpayer cooperates with reasonable IRS requests qualifying taxpayer meets applicable net-worth limitations special rules apply to penalties and statistical information
Q2.What is the stated mission of the IRS Independent Office of Appeals?
Resolve federal tax controversies without litigation on a fair and impartial basis.
Q3.A taxpayer disagrees with proposed IRS examination changes and wants administrative review without immediately litigating. Which forum fits Publication 5's mission?
The IRS Independent Office of Appeals. Publication 5 identifies the Independent Office of Appeals as the administrative forum for resolving tax controversies without litigation.
Q4.What threshold rule applies to request for appeals consideration (e.g., preparation, elements contained)?
A request for Appeals consideration must contain the information required for the applicable protest or small-case request.
Q5.How does current authority treat enrolled Agent appearance at appeals conference?
An EA may appear at an IRS Appeals conference when eligible to practice and authorized by the taxpayer.
Q6.Armando's tax return was selected for audit, and he went through the examination. He was represented by Ginny, an unenrolled preparer with an AFSP certificate. Ginny prepared the return under audit. Armando wishes to appeal the examination, and prefers that Ginny represent him before IRS Appeals. What are his options?
Ginny cannot represent him before IRS Appeals. Armando may represent himself or hire an enrolled practitioner (CPA, attorney, or EA) to represent him at the Appeals level.
Q7.Which of the following best states the purpose of the IRS Independent Office of Appeals?
To help the taxpayer and the government settle their tax dispute and reach an equitable settlement.
Q8.Gamila owes a substantial sum to the IRS. She files a petition with the U.S. Tax Court. Her case is later determined to be frivolous, wholly without merit, and merely to cause delay. As a repercussion to Gamila's action, the Tax Court may impose a penalty of:
Up to $25,000.
Q9.A Statutory Notice of Deficiency is also known as a "90-day letter" because:
Taxpayers have 90 days from the date of the letter to file a petition with the U.S. Tax Court.
Q10.Kevin and Javier are general partners in FastLane Auto Repair, a body shop business. The partnership elected-out of the Centralized Partnership Audit Regime. Both had their individual returns examined, in separate examinations, and based on how each of them treated flow-through items from the partnership, the IRS assessed additional tax on both Kevin and Javier. However, both of them disagreed with the IRS. Kevin decided to take his case to the IRS Appeals office. After the conference, he and the IRS still disagreed. Javier decided to bypass the Appeals office altogether and go directly to court. Which of the following statements is correct?
Both Kevin and Javier can take their cases to the following courts: U.S. Tax Court, U.S. Court of Federal Claims, or the U.S. District Court.
Q11.Alyssa disagrees with the IRS examiner regarding the outcome of her recent audit. Her appeal rights are explained to her, and she decides to contest the tax by pursuing the case in the U.S. Tax Court. Which of the following statements is correct?
Alyssa must receive a Notice of Deficiency before she can petition the U.S. Tax Court.
Q12.Which of the following statements is correct regarding a taxpayer's right to appeal a tax assessment?
A taxpayer must first pay the contested tax before they can appeal in a U.S. District Court.
Q13.Geraldine is an EA. Which of the following tasks can she perform on behalf of a client?
Prepare and sign a protest to challenge examination results in the IRS Appeals Office.
Q14.Vivian's return went under examination, and she disagreed with the findings of the IRS. She filed a formal protest, and her case was then sent to the IRS Office of Appeals. What happens if Vivian and the IRS Appeals Office cannot reach an agreement?
The IRS will issue a notice of deficiency, giving Vivian the right to challenge the proposed deficiency in the U.S. Tax Court.
Q15.If a taxpayer and the IRS fail to settle a non-docketed examination controversy in the IRS Appeals Office, the next event to occur is:
Issuance of a notice of deficiency.
Q16.If a taxpayer wishes to challenge the IRS in a District Court, the taxpayer must:
Pay the contested liability first and then sue the IRS for a refund.
Q17.Under which of the following conditions would it be likely that the IRS will reopen a closed examination case to make an unfavorable adjustment and assess additional tax?
There was fraud or misrepresentation in the original examination.
Q18.An Enrolled Agent may NOT represent a taxpayer in a dispute before:
A U.S. District Court judge.
Ready to move on?
- ▸ Explain at least 80% of these 18 rules without opening the answer, twice on different days.
- ▸ Score 80% across 18 or more mapped questions over two sessions, not one memorized round.
- ▸ Complete a timed Part 3 mock and return to this unit if its concepts remain flagged or missed.
Use these checks to choose your next study action. They do not predict a PSI scaled score.