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SELECTION OF RETURNS FOR AUDIT
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PREPARATION FOR AN AUDIT EXAMINATION 8 I
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accountant advice AICPA amended amount Appeals Officer apply assessment assets attorney audit bankruptcy Banoff Big Bad Wolf carryback cash Chicago Circular 230 claim for refund client Code Section corporation criminal tax deduction deﬁned deﬁnition determine documents facts filed ﬁnal regulations ﬁrm fraud Illinois imposed income tax Internal Revenue Code Internal Revenue Service interview investigation issue litigation ment motion negligence niles OFFERS IN COMPROMISE partner payment person position Preamble preparer penalty prior proposed regulations prosecution realistic possibility standard reasonable cause records respect responsible return or claim return preparer revenue agent Revenue Officers revenue procedure revenue ruling settlement special agent statement statute statutory substantial authority supra Tax Court Rule Tax Division tax fraud tax liability tax retum tax return tax shelter tax treatment taxable taxpayer tion transaction Treas trial underpayment understatement United United States Attorney valuation misstatement