Statement on Standards for Tax Services No. 1 establishes as a basic principle of providing tax services that the CPA:

a. Must have a good faith belief that the tax return position will be accepted by the IRS

b. Can never recommend a tax position to the client when it is more likely than not to be challenged by the IRS

c. Must have a good faith belief that the tax return position has a realistic possibility of success if challenged by the IRS

d. Can never recommend a tax position to the client without disclosing it to the SEC