1. C-Ment Industries, Inc. is in the business of designing, manufacturing and selling concrete equipment vehicles. In 2004, C-Ment designed and manufactured a line of concrete pumping vehicles to transfer concrete from cement mixers to specific points within a construction site. The pumping equipment is mounted on a specifically modified truck chassis.

A. C-Ment wishes to ensure that the concrete pumping vehicles are not subject to excise tax under Internal Revenue Code Section 4501.

(1) With what level of the IRS will C-Ment have to deal?
(2) With which office?

B. Assume that C-Ment goes ahead with the sale of the concrete pumping vehicles without seeking assurances as to the excise tax consequences from the IRS. Two years later its excise tax returns are reviewed.

(1) Who determines if the returns should be audited?
(2) To what level of the IRS are C-Ment's returns sent if it is determined that it will be necessary to contact the corporation during the audit process?

C. In discussing this case with the IRS representative, C-Ment has tried to convince the revenue agent that the corporate pumping vehicles are not subject ot excise tax. Because the agent will not concede the issue, C-Ment now seeks to get a higher level of the IRS to advise the agent that "as a matter of law" the vehicles are not subject to excise tax under Section 4051.

(1) What level of the IRS would make that determination?
(2) How would C-Ment go about requesting IRS participation?

D. Assume that eventually the IRS determines that there is additional excise tax due as a result of C-Ment's improper accounting for the concrete pumping equipment. C-Ment wishes to seek review of that determination within the IRS.

(1) What level of the IRS must C-Ment deal with for such formal review?
(2) What formalities must C-Ment follow?

E. Assume that eventually the IRS determination is upheld throughout the formal review and that C-Ment is sent a bill for the tax due from the deficiency.

(1) What level of the IRS sends the bill to C-Ment?
(2) Where can C-Ment make payment of the amount of this bill?

F. Because of financial difficulties, C-Ment is not in a position to pay this bill in full.

(1) With what level or levels of the IRS will C-Ment deal in attempting to resolve the unpaid bill?
(2) If personal contact with C-Ment is required to resolve the problem, who will make the contact?