[kanba]

I have two questions. Could anyone to help explain them? Thank you.

1. Which of the following acts constitutes representation before the IRS?

a. preparing a tax return for a corporate taxpayer.

b. executing a closing agreement on behalf of a corporate taxpayer

c. appearing as a witness for a taxpayer before the IRS.

d. furnishing information at the request of the IRS or any of its officers or employees.

The answer is “b”. I cannot understand why “d” is not a correct answer since I found in my Becker which stated that furnishing IRS-requested information is an obligation of practitioners. However, Gleim said preparing necessary documents and files them with the IRS for a taxpayer is practicing before IRS but furnishing inforation is not.

2. Parc contracted with Furn Brothers Corp. to buy hotel furniture on behalf of Global Motor House, a motel chain. Global instructed Parc to use Parc’s own name and not to disclose to Furn that Parc was acting on Global’s behalf. Who is liable to Furn on this contract.

Parc Global

a. Yes Yes

b. Yes No

The answer is “a”. but I think it should be “b” because according to Becker, an agent of undisclosed principal has liability but not the undisclosed principal. Here Global is the undisclosed principal without liability to the third part, Furn and Parc, as an agent is liable.