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An accuracy-related penalty is imposed on a tax preparer who fails to meet this level of certainty as to success when taking a questionable position

An accuracy-related penalty is imposed on a tax preparer who fails to meet this level of certainty as to success when taking a questionable position on a taxpayers return that results in an understatement of the taxpayers liability.

Question 5 options:

1) The preparer has a reasonable belief that more likely than not the position will be sustained on its merits, if challenged by the Service.
2) The preparer has a reasonable belief that position is not frivolous.
3) The preparer has a reasonable belief that the position has a realistic possibility of being sustained on its merits, if challenged by the Service.
4) The preparer has no reasonable doubt that the position will be sustained on its merits, if challenged by the Service.
5) None of the above.

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