Amanda, who is a tax preparer, filed a return this year that took a position which she knew or should have known was incorrect. A penalty may be imposed against her unless she can show that:

The understatement was not willful or reckless.

She did not personally profit from the understatement.

She disclosed the penalties for understatement of tax liability to her client and her client chose to sign the return anyway.

She had reasonable cause to take the position, and she acted in good faith.