Section 1: 10–20%R2
Federal Tax Procedures, Penalties, and Statutes of Limitations
Exam Insight
The statute-of-limitations rules and the penalty percentages are pure point-grabbers — the AICPA expects you to know that omitting more than 25% of gross income extends the period to 6 years and that fraud is unlimited. Choosing the right court after a 90-day letter is another recurring tested decision.
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What AICPA Wants You to Know
- 1State the general 3-year assessment statute and its 6-year and unlimited extensions
- 2Distinguish the assessment statute from the 10-year collection statute
- 3Compute the failure-to-file and failure-to-pay penalties and their interaction
- 4Apply the accuracy-related (20%) and civil fraud (75%) penalties
- 5Apply preparer penalties under §6694 and §6695
- 6Trace the audit, appeals, and litigation path, including the 90-day letter and court choices