Elements:
1. Evade assessment or payment
2. Additional Tax due and owing
3. Willfulness - Correct Answer IRC 7201 - Evasion
Elements
Elements:
1. Required to file
2. Failed to File
3. Willfulness - Correct Answer IRC 7203 - Failure to File
Elements
Elements:
1. Filed a return
2. that was materially false
3. made under penalty of perjury
4. Willfulness
5. Did not believe return was materially correct - Correct Answer IRC 7206 (1) - Filing a
false return
Elements
Elements:
1. Assisted in preparation or presentation of
2. return was false as to a material matter
3. Wilfullness - Correct Answer IRC - 7206 (2) Aiding and Abetting a False Return
Elements
Elements
1. Duty to pay tax
2. failure to pay tax
3. Willfulness - Correct Answer IRC 7202 - Employment Tax (Failure to Collect/Pay Over
Tax)
Elements
Elements
1. a corrupt attempt
2. to impede or obstruct
3. administration of IRC - Correct Answer IRC 7212 - Obstruction
Elements
6 Years - Correct Answer What is the general S.O.L. for Title 26 offenses
Element - Correct Answer An item required to be proven beyond a reasonable doubt to
prosecute a case
, Venue - Correct Answer A place where the prosecution of the D may take place
Generally it is the district where it is offense was begun, continued, or completed
Willfulness - Correct Answer Voluntary, Intentional violation of a known legal duty
Statute of Limtations - Correct Answer Date by which the charging of a person must occur
S.O.L. for a return filed on 3/13/2020 - Correct Answer 4/15/2026
S.O.L. for a return filed on 6/16/2020 (no extension) - Correct Answer 6/16/2026
S.O.L. for a return filed on 7/21/2020 (extension was filed) - Correct Answer 7/21/2026
S.O.L for a return not filed for TY 2020 (extension was filed) - Correct Answer 10/15/2026
S.O.L for a return not filed for TY 2020 (no extension) - Correct Answer 4/15/2026
Tax Due and Owing - Correct Answer Key Element to IRC 7201
An affirmative act is not a failure to act - Correct Answer An affirmative act is not a failure to
act
6050i - Correct Answer Failure to file for 8300, a felony
Spies Evasion - Correct Answer Willful failure to file coupled with an affirmative act
Affirmative Act - Correct Answer A physical act
If the jurat is crossed out, which IRC code cannot be met - Correct Answer 7606(1)
Material Item - Correct Answer any item which effects either the computation or processing
of the return
Is actually preparation of a return required for 7606(2) - Correct Answer No
What IRC code typically involves form 941 - Correct Answer IRC 7202
Does a D need to be aware of an investigation for a 7212 Obstruction charge? - Correct
Answer Yes
What precedent did Spies set? - Correct Answer An affirmative act for 7201 needs to be a
physical act not a failing to act
What IRC code do we use when we cannot nail an exact amount of tax due? - Correct
Answer 7206(1)