The Interpretative guidance of SSTS No$.$ I provides which guidance regarding potential penalty consequences of tax return positions?

a$.$ Practitioners should advise clients about potential penalty consequences of tax return positions and provide an opportunity to avoid penalties through disclosure.

b$.$ Practitioners should remain confident with their legal analysis on tax positions taken on a tax return and, therefore, never disclose the tax positions.

c$.$ To avoid worrying clients, practitioners should not share penalty risks related to tax return tax positions.

d$.$ Practitioners should hide tax positions at risk of penalty consequences by grouping them with other activities on a tax return.