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(4) When the IRS asserts the 6662 accuracy-related penalty against your client, of what significance (if any) is it that the subject return position was

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(4) When the IRS asserts the 6662 accuracy-related penalty against your client, of what significance (if any) is it that the subject return position was sup- ported by - 1. a "reasonable basis" tax opinion prepared by you? 2. a "substantial authority" tax opinion prepared by you? 3. a "more likely than not" tax opinion prepared by you? (As to each of these three scenarios, your opinion did of course reflect a correct analysis of the relevant tax authorities as of the date you delivered it, which was the same day on which your client's tax return was filed.)

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