FDDA must include which of the following as part of its essential content?

• A. It must include the specific facts of the case and the applicable law
• B. It must include the taxpayer's signature
• C. It must include the tax period
• D. It must include an advisory on penalties

Answer: (A)

The essential content must lay out the specific facts of the case and the applicable law used to decide it. This pairing is the backbone because it shows exactly what happened and why the law supports the decision, making the rationale clear and reviewable. Without the facts tied to the legal authority, the decision would be opaque and hard to justify.

An accompanying taxpayer signature, the tax period, or an advisory on penalties may appear in related documents, but they do not establish the reasoning behind the determination. The facts and the law provide the substantive basis for the FDDA, which is why this option is the best fit.