About This Book vii
How To Use This Book ix
Foreword xi
Acknowledgments xiii
About the Author xv
Chapter 1
Initial Client Engagement 5
Topical Index 1
1.01 Nature of Federal Tax Law 5
1.02 Role of the Internal Revenue Service 7 1.02(a) Specific Functions of the Internal Revenue Service 7 1.03 Organization of the Internal Revenue Service 9
1.03(a) Examination Process 11
1.03(b) Collection Process 13
1.03(c) The Criminal Investigation Division (CID) 16
1.03(d) Appeals Branch 18
1.03(e) District Counsel 18
1.04 Where Do Tax Clients Come From? 18
1.05 The Initial Consultation 19
1.06 Beginning the Engagement—Form 2848 22
1.07 Rules of Practice 24
Practice Points
Exhibit 1-1 New IRS Organization Structure 10 Exhibit 1-2 Pre-Payment Appeal Process Examination 12 Exhibit 1-3 Post-Payment Appeal Process Examination/Claims 14
Exhibit 1-4 The Collection Process 15
Exhibit 1-5 The Criminal Process 17
Exhibit 1-6 Initial Client Engagement Checklist 32 Exhibit 1-7 Form 2848, Power of Attorney 33 Exhibit 1-8 Form 8821, Tax Information Authorization 35 Exhibit 1-9 Form 56, Notice Concerning Fiduciary Relationship 37
xvii
Exhibit 1-10 Form 4506, Request for Copy or Transcript of Tax Form 39 Exhibit 1-11 CAF Fax Numbers (to Fax Form 2848) 41 Exhibit 1-12 Initial Client Representation Letter 42
Exhibit 1-13 Sample Retainer Agreement 43
Exhibit 1-14 Sample Client Conflict of Interest Letter 45 Exhibit 1-15 Sample Initial Letter to IRS (on CD-ROM only)
Exhibit 1-16 Sample Memo to File (on CD-ROM only)
Exhibit 1-17 IRS Publication: Your Rights as a Taxpayer (on CD-ROM only) Exhibit 1-18 List of Useful IRS Publications (on CD-ROM only)
Chapter 2
Examination of Returns 49
Topical Index 47
2.01 Audit Basics 49
2.02 Pre-Audit Action by Practitioner 53
2.03 Conducting the Audit Examination 56
2.04 Closing the Audit Examination 59
2.04(a) Statute of Limitations Extension Issues 61 2.05 Jeopardy and Termination Assessments 63 2.06 Coordinated Examination Program (CEP) 64
2.07 Partnership Audit Problems 65
Practice Points
Exhibit 2-1 Examination of Returns Checklist 54 Exhibit 2-2 How To Recognize an Eggshell Audit 55 Exhibit 2-3 Initial Examination Conference Checklist 57 Exhibit 2-4 Ten Negotiating Techniques that Work and Ten that Don’t 60 Exhibit 2-5 Closing the Examination Checklist 62 Exhibit 2-6 IRS Audit Notice—Corporation 72
Exhibit 2-7 IRS Audit Notice—Individual 73
Exhibit 2-8 Thirty-Day Notice 76
Exhibit 2-9 Letter 3164—Notice of Third Party Contact 81 Exhibit 2-10 List of IRS Market Segment Papers 82 Exhibit 2-11 List of Industry Specialization Papers 84 Exhibit 2-12 Form 870—Waiver of Restrictions on Assessment and Collection
of Deficiency in Tax and Acceptance of Overassessment 86 Exhibit 2-13 Form 1902-B—Report of Individual Income Tax
(on CD-ROM only)
Exhibit 2-14 Form 4549-E—Income Tax Discrepancy Adjustments (on CD-ROM only)
Exhibit 2-15 Form 4549-CG—Income Tax Examination Changes (on CD-ROM only)
Exhibit 2-16 Form 3552(C)—Notice of Tax Due on Federal Tax Return (Assessment Document) (on CD-ROM only)
Exhibit 2-17 Letter Form 921(DO)—IRS Proposed Examination Changes for Partner, Shareholder, Beneficiary or Grantor (on CD-ROM only) Exhibit 2-18 Form 4089—Notice of Deficiency Waiver 87 Chapter 3
Statute of Limitations 93
Topical Index 89
3.01 The Statutes of Limitations in Tax Matters 93 3.02 Statute of Limitations on Assessment 95 3.02(a) Extensions of the Statute of Limitations on Assessment 97 3.03 Statute of Limitations on Collection 98 3.04 Statute of Limitations on Claims for Refund 100 3.05 Statute of Limitations on Assessment of Trust Fund Liability: § 6672 102 3.06 Special Rules for Suspension on the Statute of the Statute of
Limitations—Mitigation 103
3.07 Transferee Liability 104
3.08 Limitations Period for Criminal Prosecution 105 Practice Points
Exhibit 3-1 Major Statutes of Limitation 94 Exhibit 3-2 Statute of Limitations Checklist 113 Exhibit 3-3 Suspension of Statute of Limitation 114 Exhibit 3-4 Extend Assessment Statute in Criminal Case 115 Exhibit 3-5 Sample Letter to Client: Trust Fund Penalty Extension 116 Exhibit 3-6 Sample Letter to Client: To Extend Assessment Statute 117 Exhibit 3-7 Sample Letter to Client: No Extension
of the Assessment Statute 118
Exhibit 3-8 Form 843—Protective Claim (on CD-ROM only)
Exhibit 3-9 Letter907(DO)—IRS Request for Extension (on CD-ROM only) Exhibit 3-10 IRS Publication 1035—Extending the Tax Assessment Period
(on CD-ROM only)
Exhibit 3-11 Form 872—Consent To Extend the Time To Assess Tax 119 Exhibit 3-12 Form 872-A—Special Consent To Extend the Time
To Assess Tax (on CD-ROM only)
Exhibit 3-13 Form 872-T—Notice of Termination of Special Consent To Extend the Time To Assess Tax (on CD-ROM only) Exhibit 3-14 Tax Collection Waiver (on CD-ROM only)
Exhibit 3-15 Waiver Extending Statutory Period for Assessment of Trust Fund Recovery Penalty (on CD-ROM only)
Exhibit 3-16 Form 843—Claim for Refund and Request for Abatement (on CD-ROM only)
Exhibit 3-17 Form 1040X—Amended U.S. Individual Income Tax Return (on CD-ROM only)
Chapter 4 Administrative Summons 123 Topical Index 121 4.01 Nature of Summons 123 4.02 Summons Enforcement 125 4.03 Compliance Considerations 126
4.04 Defenses to Summons and Right To Quash 128 Practice Points
Exhibit 4-1 Administrative Summons Checklist 134 Exhibit 4-2 Practitioner Objections to Summons 135 Exhibit 4-3 Request for Third Party Contact List 136 Exhibit 4-4 Form 2039: Client Summons—Examination Division 137 Exhibit 4-5 Form 6638: Summons for Income Tax Return—
Collection Branch (on CD-ROM only)
Exhibit 4-6 Form 2039: Summons—Criminal Division (on CD-ROM only) Exhibit 4-7 Form 6637: Summons for Collection Information Statement—
Collection Branch (on CD-ROM only)
Exhibit 4-8 Summons for Handwriting Exemplar—Criminal Division (on CD-ROM only)
Exhibit 4-9 Form 6540: Handwriting Exemplars (on CD-ROM only)
Exhibit 4-10 Form 4564: Information Document Request (on CD-ROM only) Exhibit 4-11 Letter 3164: IRS Third Party Contact Letter (on CD-ROM only) Exhibit 4-12 Form 6882: IDRS/Master File Information Request
(on CD-ROM only)
Exhibit 4-13 Form 6863: Request for Expenses Incident to Summons (on CD-ROM only)
Exhibit 4-14 Grand Jury Subpoena (on CD-ROM only)
Exhibit 4-15 Petition To Quash Summons 139
Chapter 5
Appeals Branch 143
Topical Index 141
5.01 Nature of Appeals Branch 143
5.02 Protest Filing 146
5.03 The Appeals Hearing 149
5.04(a) Appeals Binding Arbitration 152 5.04(b) Collection Due Process Hearings 153 Practice Points
Exhibit 5-1 Advantages/Disadvantages of Appeals Hearing 145 Exhibit 5-2 When Not To File a Protest to Appeals 148
Exhibit 5-3 Appeals Branch Checklist 163
Exhibit 5-4 IRS Thirty-Day Letter 165
Exhibit 5-5 Sample Protest: Income Tax 168
Exhibit 5-6 Sample Protest: §6672 Trust Fund Recovery Penalty 169 Exhibit 5-7 Sample: Appeals Protest Transmittal Letter 172 Exhibit 5-8 Appeals Acknowledgement and Notice of Appeals Hearing 173 Exhibit 5-9 Your Appeal Rights and How To Prepare a Protest
If You Don’t Agree (on CD-ROM only)
Exhibit 5-10 Form 870-AD: Offer of Waiver of Restrictions on Assessment and Collection of Deficiency in Tax and Acceptance
of Overassessment (on CD-ROM only)
Exhibit 5-11 Form 906: Closing Agreement on Final Determination Covering Specific Matters (on CD-ROM only)
Exhibit 5-12 IRS Letter 913 (RO): Appeals Approval of Settlement (on CD-ROM only)
Exhibit 5-13 Sample: Letter to IRS To Request (on CD-ROM only) Collection Due Process Hearing (on CD-ROM only) Exhibit 5-14 Form 12153: Request for Post-Lien/Pre-Levy Collection
Due Process Hearing 174
Exhibit 5-15 Sample: Letter to Client
Re: Collection Due Process Hearing (on CD-ROM only) Exhibit 5-16 Model Arbitration Agreement (on CD-ROM only) Chapter 6
Collection Branch 181
Topical Index 177
6.01 Nature of Collection 181
6.02 Service Center Collection Activity 182
6.03 ACS 183
6.04 District Office 184
6.05 Notices and Forms Filing 186
6.06 Tax Liens 187
6.07 Tax Levies 190
6.08 Taxpayers Advocate Service 192
6.09 Offers in Compromise 193
6.09(a) Collateral Agreements and Post Submission Procedures 203
6.10 Bankruptcy 205
6.11 Principal Residence 206
6.12 Re-Audits 207
6.13 Installment Agreements 208
6.14 Actions To Enjoin IRS 209
6.15 Employment Tax Assessments 210
6.16 Innocent Spouse §6915 211
6.17 Judicial Review of Collection Action 214 Practice Points
Exhibit 6-1 Getting the Offer in Compromise Accepted Checklist 201 Exhibit 6-2 Applying for Innocent Spouse Relief Checklist 213 Exhibit 6-3 Collection Due Process Hearing Requests 215 Exhibit 6-4 Collection Branch Checklist 230
Exhibit 6-5 The Collection Process 231
Exhibit 6-6 IRS Letter 2843—Notice of Processable Offer
in Compromise and Request for Verification 232 Exhibit 6-7 Application for Certificate of Subordination 234 Exhibit 6-8 Application for Certificate of Discharge 237 Exhibit 6-9 IRS Notice CP-504—Urgent Collection Notice 240 Exhibit 6-10 IRS Notice CP-523—Notice of Intent To Terminate
an Installment Agreement and To Levy 241 Exhibit 6-11 Form 433-A—Collection Information Statement
for Individuals 242
Exhibit 6-12 Form 433-B—Collection Information Statement for Businesses 246 Exhibit 6-13 Form 433-D—Installment Agreement 250 Exhibit 6-14 Form 433-F—Collection Information Statement (Short Form) 251 Exhibit 6-15 IRS Letter 3283(DO)—IRS Innocent Spouse
Determination Letter 254
Exhibit 6-16 IRS Publication 594—The IRS Collection Process (on CD-ROM only)
Exhibit 6-17 IRS Innocent Spouse Questionnaire (on CD-ROM only) Exhibit 6-18 Form 911—Application for Taxpayer Assistance Order (ATAO)
(on CD-ROM only)
Exhibit 6-19 Form 8857—Request for Innocent Spouse Relief (on CD-ROM only)
Exhibit 6-20 Letter 1153 (DO)—Notice of Proposed Trust Fund Recovery Penalty with Protest Instruction (on CD-ROM only)
Exhibit 6-21 Form 2751—Proposed Assessment of Trust Fund Recovery Penalty (Agreement Form) (on CD-ROM only)
Exhibit 6-22 Form 12153—Request for Collection Due Process Hearing with Instructions (on CD-ROM only)
Exhibit 6-23 IRS Letter of Notice of Determination Concerning Collection Actions under Section 6320 and/or 6330 (on CD-ROM only) Exhibit 6-24 IRS Publication 1660—Collection Appeal Rights
(on CD-ROM only)
Exhibit 6-25 IRS Publication 1450—Instructions on How To Request a Release of Federal Tax Lien (on CD-ROM only)
Exhibit 6-26 IRS/ACS Letter 726—Notice of Amount Due on Tax Account (on CD-ROM only)
Exhibit 6-27 Form 668(W)—Notice of Levy on Wages, Salary, and Other Income (on CD-ROM only)
Exhibit 6-28 Form 668(Y)—Notice of Federal Tax Lien (on CD-ROM only) Exhibit 6-29 Form 669-A—Certificate of Discharge of Property from Federal
Tax Lien (on CD-ROM only)
Exhibit 6-30 Form 669-D—Certificate of Subordination of Federal Tax Lien (on CD-ROM only)
Exhibit 6-31 IRS Publication 783—Instructions on How To Apply for Certificate of Discharge of Property from Federal Tax Lien (on CD-ROM only)
Exhibit 6-32 IRS Publication 784—How To Prepare Application for Certificate of Subordination of Federal Tax Lien (on CD-ROM only)
Exhibit 6-33 Form 656—Offer in Compromise (on CD-ROM only)
Exhibit 6-34 Form 4180—IRS Trust Fund Recovery Penalty Interview Form (on CD-ROM only)
Exhibit 6-35 Form 668-D—Release of Levy/Release of Property from Levy (on CD-ROM only)
Exhibit 6-36 Form 668-Z—Release of Federal Tax Lien (on CD-ROM only) Exhibit 6-37 Taxpayer Advocate Service Acknowledgment Letter 256 Exhibit 6-38 Form 668-A(c)—Notice of Levy 257 Exhibit 6-39 Form Letter 1058—Notice of Intent to Levy
and Right to a Hearing 258
Exhibit 6-40 Form Letter 3172—Notice of Tax Lien Filing
and Your Right to a Hearing 261
Chapter 7
Criminal Tax 265
Topical Index 263
7.01 Nature of Criminal Investigation Division 265
7.02 Specific Procedure 266
7.03 Grand Jury Investigations—Alternative IRS Investigation 269
7.04 Dealing with Special Agents 270
7.05 Crimes Investigated by IRS 273
7.06 Negotiating the Plea Agreement 277
7.07 Hearings in District Court for Criminal Violation—Plea Hearing 278
7.08 Sentencing Hearing 279
7.09 Defenses to Criminal Violations 281
7.10 SEP 281
Practice Points
Exhibit 7-1 The Criminal Process 267
Exhibit 7-2 Ten Badges of Criminal Tax Fraud 272 Exhibit 7-3 Title 26—Criminal Penalties and Fines 276
Exhibit 7-4 Sentencing Options by Zone 280
Exhibit 7-5 Criminal Tax Checklist 292
Exhibit 7-6 Criminal Tax Appeals Checklist 293 Exhibit 7-7 Rule 11 Plea Hearing Checklist 294 Exhibit 7-8 Sentencing Hearing Checklist 295
Exhibit 7-9 Kovel-CPA Agreement 296
Exhibit 7-10 Sentencing Table 298
Exhibit 7-11 Table Showing Relationship Between
Tax Loss and Offense Level 299
Exhibit 7-12 Toughest and Most Lenient States for White Collar Crime 300 Exhibit 7-13 Request for Conference at U.S. Department of Justice 301 Exhibit 7-14 Memo to Client Regarding Rule 11 Proceedings
in Federal Tax Crimes 302
Exhibit 7-15 Sentencing Hearing 306
Exhibit 7-16 Defense Memorandum 308
Exhibit 7-17 Request for Conference at U.S. Attorney’s Office 312 Exhibit 7-18 Contents of Special Agent’s Report 313 Exhibit 7-19 Request for Conference at District Counsel 314 Exhibit 7-20 Referral Report of Potential Criminal Fraud Cases 315 Exhibit 7-21 Application for Permission To Enter Plea of Guilty 317 Exhibit 7-22 District Court Order of Release 324 Exhibit 7-23 District Court Waiver of Indictment 325 Exhibit 7-24 Sample: Assistant U.S. Attorney Letter to Judge Regarding
Allocution Questions 326
Exhibit 7-25 Sample: Justice Department Acknowledgment Letter 330 Exhibit 7-26 Explanation of the Pre-Sentence Report (on CD-ROM only) Exhibit 7-27 United States District Court’s Conditions of Probation and
Supervised Release (on CD-ROM only)
Exhibit 7-28 Sample: Plea Agreement 331
Exhibit 7-29 Sample: U.S. Probation Report; Presentence Investigation Report with Probation Cover Letter (on CD-ROM only) Exhibit 7-30 Standing Order of U.S. District Court (on CD-ROM only)
Chapter 8
Tax Court Practice 339
Topical Index 337
8.01 Nature of Tax Court 339
8.02 Admission to Practice 342
8.03 Petition Filing 343
8.04 Trial Practice 346
8.05 Small Case Procedure 348
8.06 Motion Practice 352
8.07 Other Areas of Tax Court Jurisdiction 354
8.08 Burden of Proof 356
8.09 Claims for Litigation and Administrative Costs 357
8.10 Appeals 359
Practice Points
Exhibit 8-1 Advantages/Disadvantages of U.S. Tax Court 341 Exhibit 8-2 Emergency Petition—U.S. Tax Court 344 Exhibit 8-3 Format for Briefs—Tax Court 349 Exhibit 8-4 Format and Style for Papers Filed in Tax Court 350
Exhibit 8-5 U.S. Tax Court Checklist 366
Exhibit 8-6 Statutory Notice—IRS Form 5601 367
Exhibit 8-6A Entry of Appearance 368
Exhibit 8-7 Sample: Petition 369
Exhibit 8-8 Decision Document and IRS Transmittal Letter 371 Exhibit 8-9 Sample: Petitioner’s Request for Production of Documents 376
Exhibit 8-10 Tax Court List of Cities 378
Exhibit 8-11 Sample: Designation of Place of Trial (on CD-ROM only) Exhibit 8-12 Sample: IRS Answer to Petition (on CD-ROM only) Exhibit 8-13 Notice Setting Case for Trial (on CD-ROM only) Exhibit 8-14 Standing Pre-Trial Order (on CD-ROM only) Exhibit 8-15 Form of Trial Memorandum (on CD-ROM only) Exhibit 8-16 Tax Court Subpoena (on CD-ROM only)
Exhibit 8-17 Tax Court Form of Petition (on CD-ROM only) Exhibit 8-18 Tax Court Election of S Case Procedure and Forms
(on CD-ROM only)
Exhibit 8-19 Tax Court Form: Petition for Administrative Costs (on CD-ROM only)
Exhibit 8-20 Tax Court Form: Application for Order To Take Depositions (on CD-ROM only)
Chapter 9
Claims Practice 381
Topical Index 379
9.01 Claims Basics 381
9.02 Statute of Limitations 383
9.03 Full/Divisible Payment Rules 386
9.04 IRS Claims Procedure 387
9.05 Resort to Courts 389
9.06 Choice of Judicial Forum 389
9.07 Claim Look-Alikes 390
9.08 Tax Payments 391
Exhibit 9-1 Chart: Claims Procedure 382
Exhibit 9-2 Suspension under § 6511(h) Disability Checklist 385 Exhibit 9-3 Claim Elements: Informal Claim Doctrine 388
Exhibit 9-4 Claims Checklist 397
Exhibit 9-5 Letter Form 569: Thirty Day Notice 399 Exhibit 9-6 Memorandum in Support of Claim 401 Exhibit 9-7 Protective Claim on Form 843 404 Exhibit 9-8 Letter Form 906: Notice of Claim Disallowance 405 Exhibit 9-9 Form 2297: Waiver of Statutory
Notification of Claim Disallowance 408 Exhibit 9-10 Form 843: Claim for Refund or Abatement 409 Exhibit 9-11 Form 1040X: Amended Individual Tax Return
and Instructions for Filing 410
Exhibit 9-12 Form 1120X: Amended Corporate Tax Return 412 Exhibit 9-13 Form 1045: Application for Tentative Refund 414 Exhibit 9-14 Form 1139: Corporation Application for Tentative Refund 418 Exhibit 9-15 Form 870-AD: Appeals Settlement Promising
No Claim Filing (on CD-ROM only)
Exhibit 9-16 Form 1310: Statement of Person Claiming Refund Due for a Deceased Taxpayer (on CD-ROM only)
Chapter 10
Obtaining Information and Assistance from IRS 423
Topical Index 421
10.01 Obtaining Background Information 423
10.02 Filing FOIA Requests 426
10.03 Obtaining IRS Information On-Line 426 10.04 Resolving Taxpayer Problems with the IRS 426
10.05 IRS Publications 427
10.07 Obtaining Private Letter Rulings and Determination Letters 428
10.08 Tax and Legal Web Sites 434
Exhibit 10-1 Hierarchy of Tax Authorities 424
Exhibit 10-2 Applying for IRS Rulings 429
Exhibit 10-3 Format for Most Ruling Requests 430 Exhibit 10-4 Obtaining Information and IRS Assistance Checklist 440
Exhibit 10-5 Tax and Legal Web Sites 441
Exhibit 10-6 IRS Transaction Codes 443
Exhibit 10-7 Schedule of Typical User Fees 445 Exhibit 10-8 Freedom of Information Act (FOIA) Request
to District Disclosure Officer 446
Exhibit 10-9 Help with Unresolved Tax Issues 448 Exhibit 10-10 Taxpayer Advocate Directory 449 Exhibit 10-11 Form 4506: Request for Copy or Transcript of Tax Form 451 Exhibit 10-12 The Digital Daily: IRS Newsletter (on CD-ROM only)
Exhibit 10-13 Forms and Publications from IRS Web Site (on CD-ROM only) Exhibit 10-14 Tax Information for Businesses from IRS Web Site
(on CD-ROM only)
Exhibit 10-15 Tax Information for Individuals from IRS Web Site (on CD-ROM only)
Exhibit 10-16 Special Report: IRS Problem Solving Day from IRS Web Site (on CD-ROM only) Chapter 11
Penalties and Interest 457
Topical Index 453
11.01 Accuracy Related Penalty—Negligence Penalty 457
11.02 Civil Fraud Penalty 459
11.03 Innocent Spouse Defense to Penalties 461 11.04 Substantial Understatement of Tax—Section 6662(b)(2) 463 11.05 Substantial Valuation Misstatements 464 11.06 Substantial Estate or Gift Tax Valuation Understatement 464
11.07 Failure To File Returns 464
11.08 Failure To Pay Tax 465
11.09 Estimated Tax Penalty 467
11.10 Failure To Timely Deposit 468
11.11 Trust Fund Recovery Penalty 469
11.12 Defense of Reasonable Cause 472
11.13 Penalty Appeal Procedure 476
11.14 Third Party Penalties 478
11.15 Interest 479
11.16 Abatement of Interest 481
11.17 Miscellaneous 483
Exhibit 11-1 Most Often Assessed Penalties 458 Exhibit 11-2 Obtaining Equitable Innocent Spouse Relief—§ 6015(f ) 462 Exhibit 11-3 Trust Fund Recovery Penalty Checklist 471 Exhibit 11-4 Does Reasonable Cause Exist? 474 Exhibit 11-5 Penalty Appeal Procedure Checklist
(Post Assessment Prepayment of Penalties) 477 Exhibit 11-6 Schedule of Interest Rates 480 Exhibit 11-7 How To Apply for Zero Interest Netting 482 Exhibit 11-8 Interest Abatement Procedure Checklist 485 Exhibit 11-9 Form 8275—Disclosure Statement 501 Exhibit 11-10 Letter 1277—IRS Penalty Appeal Determination Letter 503 Exhibit 11-11 Sample—Penalty Appeal Request on Form 843 504 Exhibit 11-12 Sample—Letter Requesting Penalty Appeal Consideration 508 Exhibit 11-13 Procedures for Taxpayers To Make Remittances To Stop the
Running of Interest on Deficiencies (on CD-ROM only) See also the following Exhibits in other chapters:
Exhibit 5-6 Sample Protest: §6672 Trust Fund Recovery Penalty 169 Exhibit 6-19 Form 8857—Request for Innocent Spouse Relief
(on CD-ROM only)
Exhibit 6-20 Letter 1153 (DO)—Notice of Proposed Trust Fund Recovery Penalty with Protest Instruction (on CD-ROM only)
Exhibit 6-21 Form 2751—Proposed Assessment of Trust Fund
Recovery Penalty (Agreement Form) (on CD-ROM only) Exhibit 6-34 Form 4180—IRS Trust Fund Recovery
Penalty Interview Form (on CD-ROM only)
Appendix 509
