Federal Tax Procedure and Authority

This chapter covers the procedural side of federal taxation: how returns are examined, what records and disclosures matter, when deadlines cut off action, and where authoritative support comes from. These topics are highly testable because they combine rules, timing, and judgment.

In This Chapter

• IRS Examination, Appeals, and Procedural Escalation explains the path from examination to administrative review.
• Substantiation, Disclosure, and Recordkeeping Duties covers the documentation taxpayers and preparers must support.
• Assessment Periods, Refund Windows, and Filing Deadlines explains the timing rules that affect assessment and refund claims.
• Civil Versus Criminal Tax Penalties distinguishes common penalty types and what conduct triggers them.
• Tax Authority Hierarchy for Research and Support explains how to rank sources when supporting a tax conclusion.

How to Use This Chapter

• Read this chapter when timing, documentation, or penalty questions are producing avoidable misses.
• Focus on what changes the taxpayer’s procedural position, not just the underlying tax calculation.
• Revisit it before cumulative review because tax procedure issues often appear as modifiers inside broader fact patterns.

In this section

• IRS Examination, Appeals, and Procedural Escalation
  How IRS exams move from audit to appeals and how taxpayers respond at each stage.
• Substantiation, Disclosure, and Recordkeeping Duties
  Documentation, disclosure rules, and recordkeeping duties that support tax positions.
• Assessment Periods, Refund Windows, and Filing Deadlines
  The time limits that govern assessment, refund claims, extensions, and filing obligations.
• Civil Versus Criminal Tax Penalties
  When tax noncompliance stays civil, when it becomes criminal, and what penalties apply.
• Tax Authority Hierarchy for Research and Support
  How to rank Code, regulations, rulings, and other authorities when supporting a tax conclusion.