29.4 Final Mock Review & Exam Strategy

Why This Matters for the Exam

Part 3 is unique among the three EA exam parts because it tests procedural knowledge rather than tax calculations. Success requires you to synthesize rules from multiple chapters and apply them to scenarios. This section provides cross-chapter practice and test-day strategies.

Cross-Chapter Synthesis: How Topics Connect

The exam often combines concepts from multiple chapters in a single question. Here's how the major topics interconnect:

Integrated Scenario Practice

Scenario 1: The Married Couple with a Debt Problem

Facts:

• John and Mary are married and filed jointly for 2021.
• The IRS assessed a $60,000 deficiency in March 2024.
• Mary believes the debt is entirely John's fault (he had unreported income).
• John wants to set up an Installment Agreement.
• It is now January 2027.

Questions to Consider:

1. Can Mary seek Innocent Spouse Relief? Check the deadline: 2 years from first collection notice (Traditional/Separation). If the first collection notice was in April 2024, the 2-year window closed April 2026. She may have missed Traditional/Separation but can still seek Equitable Relief under §6015(f), which has no statutory deadline.
2. Can John get a Streamlined IA? No, the debt exceeds $50,000. He must complete Form 433-F (financial statement).
3. Is the CSED in play? The assessment was March 2024. CSED is March 2034. Plenty of time for IRS to collect.
4. Can an EA represent both? Conflict of interest — Mary blames John. The EA would need written consent from both within 30 days of discovering the conflict (Circular 230 §10.29), or should decline one (or both).

Scenario 2: The CDP Hearing

Facts:

• A taxpayer receives a Final Notice of Intent to Levy dated October 15, 2026.
• The taxpayer wants to challenge the levy and propose an Offer in Compromise.

Questions to Consider:

1. Deadline for CDP Hearing: 30 days from the notice date = November 14, 2026.
2. Form to File: Form 12153.
3. What happens at the hearing? Taxpayer can challenge the appropriateness of the levy and propose alternatives (IA, OIC, CNC status).
4. If they miss the deadline? They can request an Equivalent Hearing within 1 year, but lose the right to appeal to Tax Court.

Scenario 3: The 90-Day Letter

Facts:

• A taxpayer receives a Statutory Notice of Deficiency on February 1, 2027.
• The taxpayer is in the US.
• The proposed deficiency is $25,000.

Questions to Consider:

1. Deadline to petition Tax Court: 90 days = May 2, 2027.
2. Can the taxpayer go to Appeals first? No, the 30-day window (30-Day Letter) has passed. Appeals is before the 90-Day Letter.
3. If they miss the 90-day deadline? They must pay the tax first, then sue for a refund in District Court or Court of Federal Claims.
4. Can an EA represent in Tax Court? Only if admitted to practice before the Tax Court: a nonattorney such as an EA qualifies by passing the Court's Nonattorney Examination and a character and fitness review (Tax Court Rule 200). Enrollment alone covers practice before the IRS.

Exam-Taking Strategies

Strategy 1: The 2-Minute Rule

You have 210 minutes for 100 questions. That's 2.1 minutes per question.

• If you're stuck after 90 seconds: Mark the question and move on. Come back later.
• Don't let one question cost you three: A 5-minute question uses the time budget of 2.5 questions.
• First pass: Answer everything you know immediately.
• Second pass: Return to marked questions with fresh eyes.

Strategy 2: Elimination

Before guessing, eliminate obviously wrong answers.

Example Question: "Which of the following is NOT a sanction under Circular 230?"

• A) Censure
• B) Suspension
• C) Prison
• D) Disbarment

Analysis: Circular 230 is administrative. Prison is a criminal penalty (IRC). Eliminate C immediately. Only A, B, and D are Circular 230 sanctions. Answer: C.

Strategy 3: Read the Question Carefully

Pay attention to key words:

"EXCEPT" Questions: The exam loves these. The wrong answer is the right choice. Four options are true; you're looking for the one that's false.

Strategy 4: Identify the Taxpayer's Status

Before answering, determine where the taxpayer is in the process:

Final Checklist Before Test Day

On the Exam

Practice questions that synthesize multiple chapters, such as:

1. Scenario Questions: "A taxpayer received a CDP notice and wants to propose an OIC. The EA also represents the taxpayer's ex-spouse. What issues arise?"
2. "EXCEPT" Questions: "All of the following are Circular 230 duties EXCEPT..."
3. Procedural Questions: "After receiving a 90-Day Letter, what is the taxpayer's next option?"

The key is to read carefully, manage time, and trust your preparation.