Ryan, a tax practitioner, prepares H$3$ Inc's. federal income tax return. H$3\text{'}$s tax liability is understated under the

tax law. In which situation would Ryan be most likely to be assessed an IRC Section $6694$ penalty?

H$3\text{'}$s nondisclosed tax position had substantial authority.

H$3$ had reasonable cause for the understatement, and Ryan acted in good faith.

H$3$s disclosed tax postion does not have a reasonable basis

H$3$ had reasonable doubt that the company qualified for certain tax credts.