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Business & Finance homework help. TAX 700 Final Project I Milestone Two Guidelines and Rubric
Appealing the Adjustment
Overview: For the first milestone of your Final Project I NOPA Response Plan, you provided your client with a brief explanation of their current situation, using
details from the scenario and the final project NOPA document. For Milestone Two, due in Module Four, you will complete the research necessary to make an
informed recommendation on whether to appeal the IRS adjustment, and you will complete this critical component of your NOPA Response Plan. Several factors
will influence your recommendation, including whether the relevant laws and regulations support the decision to appeal, and the materiality of the case to the
client. Be sure to thoroughly address all relevant information when formulating your recommendation, including tax regulations and information from the NOPA
and scenario, as you will need to provide a detailed explanation of how the relevant factors lead to your recommendation.
Scenario: Imagine that you are a CPA working for an accounting firm. Your client is a Fortune 500 public company that has revenues exceeding $10 billion. It is a
fast-growing company that has engaged your firm to handle all tax compliance and consulting. The client has recently received notification from the IRS, and
they have determined that they will be under audit for the prior tax year. The client contacts you to help them through this process. While meeting with the IRS
to understand what they need for their audit, you provided the IRS with your client’s trial balances, recent tax return work papers, and the tax returns
themselves.
After further review of those documents, the IRS provided your client with a Notice of Proposed Adjustment (NOPA) related to per diem expenses that the client
has been providing to their employees when they travel for business. The per diems were for the combined lodging and meal expenses. The IRS is
recommending that these per diems are nondeductible at a rate of 50 percent. The adjustment they have proposed is $5 million. While discussing the issue with
your client, you learn that they have accounted for per diem expenses the same way for the past several years in their tax returns. You estimate that the fees
associated with your services will be $250,000. This fee includes defending your client before the IRS, drafting a response plan, preparing a NOPA response, and
defending your client through an appeal.
Prompt: In this section, you will explain to your client why appealing the IRS’s proposed adjustment is an appropriate course of action by discussing all the
relevant factors that your client should consider.
 Tax Rules and Regulations: Determine the taxation laws, revenue rulings, and/or revenue procedures that apply in this scenario, and explain how they
impact your client’s current situation.
 Appeal Support: Explain which of the tax rules and/or regulations discussed above may work in your client’s favor if they appeal the IRS adjustment, and
why.
 Materiality: Determine how material this adjustment is to your client, using details from the scenario to support your conclusion. Explain why your client
should move forward with appealing the IRS adjustment, based on the information discussed above.
 Now that you established that appealing the adjustment is appropriate, explain the next steps that will occur in the IRS appeals process, including the
possible outcomes.
 Explain why the potential benefit of an appeal to your client outweighs the fees associated with your CPA services, supported by details from the
scenario. In other words, persuade your client that your services are worth the cost.
Rubric
Guidelines for Submission: Your paper must be submitted as a 3- to 4-page Microsoft Word document with double spacing, 12-point Times New Roman font,
one-inch margins, and any sources cited in APA format.
Critical Elements Proficient (100%) Needs Improvement (75%) Not Evident (0%) Value
Appealing the
Adjustment: Tax Rules
and Regulations
Determines the taxation laws,
revenue rulings, and/or
revenue procedures that apply
in this scenario and explains
how they impact the client’s
current situation
Determines the taxation laws,
revenue rulings, and/or
revenue procedures that apply
in this scenario, but does not
explain how they impact the
client’s current situation, or
response is cursory or illogical
or contains inaccuracies
Does not determine the
taxation laws, revenue rulings,
and/or revenue procedures
that apply in this scenario
20
Appealing the
Adjustment: Appeal
Support
Explains which of the tax rules
and/or regulations discussed
above may work in the client’s
favor if they appeal the IRS
adjustment and why
Explains which of the tax rules
and/or regulations discussed
above may work in the client’s
favor if they appeal the IRS
adjustment, but does not
explain why, or response is
cursory or illogical or contains
inaccuracies
Does not explain which of the
tax rules and/or regulations
discussed above may work in
the client’s favor if they appeal
the IRS adjustment
20
Appealing the
Adjustment: Materiality
Determines how material this
adjustment is to the
client, using details from the
scenario to support conclusion
Determines how material this
adjustment is to the
client, but does not use details
from the scenario to support
conclusion, or response is
illogical or contains inaccuracies
Does not determine how
material this adjustment is to
the client
15
Appealing the
Adjustment: Appealing
the Adjustment
Explains why the client should
move forward with appealing
the IRS adjustment based on
the information discussed
above
Explains why the client should
move forward with appealing
the IRS adjustment based on
the information discussed
above, but explanation is
cursory or illogical
Does not explain why the client
should move forward with
appealing the IRS adjustment
20
Appealing the
Adjustment: Next Steps
Explains the next steps that will
occur in the IRS appeals
process, including the possible
outcomes
Explains the next steps that will
occur in the IRS appeals
process, including the possible
outcomes, but explanation is
cursory or contains gaps or
inaccuracies
Does not explain the next steps
that will occur in the IRS
appeals process
10
Appealing the
Adjustment: Potential
Benefit
Explains why the potential
benefit of an appeal to the
client outweighs the fees
associated with the CPA
services, supported by details
from the scenario
Explains why the potential
benefit of an appeal to the
client outweighs the fees
associated with the CPA
services, but does not support
explanation with details from
the scenario, or response is
cursory or illogical or contains
inaccuracies
Does not explain why the
potential benefit of an appeal
to the client outweighs the fees
associated with the CPA
services, supported by details
from the scenario
10
Articulation of Response Submission is free of errors
related to citations, grammar,
spelling, syntax, and
organization and is presented in
a professional and easy-to-read
format
Submission has no major errors
related to citations, grammar,
spelling, syntax, or organization
Submission has major errors
related to citations, grammar,
spelling, syntax, or organization
that negatively impact
readability and articulation of
main ideas
5
Total 100%
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