Ben and Sally Wen, married taxpayers filed a return claiming the American Opportunity Tax Credit (AOC). They reported a total credit of $7,500 ($2,500 for each of their kids) on Form 8863, Education Credits, including a refundable portion of $3,000. Thus, they failed to carry the $4,500 nonrefundable portion of the credit to their Form 1040, due to what appears to be a clerical error. Their return simply claimed the credit without disclosing all of the facts relevant to their claim and included no Form 8275. One year later the Wens claimed a refund of $4,500 on their return. The IRS mistakenly issued a refund of $7,500. Later, the IRS disallowed the entire AOC; the Wens had already claimed the AOC for their kids in the prior four taxable years. Therefore, the IRS imposed a $1,500 accuracy-related penalty under IRC 6662(b). The Wens tell you they used FAST-TAX, tax return preparation software and any error was due to confusion with FAST-Taxs instructions. In the first paragraph write a sophisticated legal issue raised by the Wens in their last explanation to you. In the second paragraph briefly discuss the relevant code and regs related to the primary issue. (Always give accurate citations). [Grading considers finding the most relevant regulation as equally important as Code sections, as well as your precision in determining where within the most relevant Code section [not subsection (a)] and the most relevant regulation].