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The IRS examines the 20X5 tax return of Sam Short. His return reported tax due in the amount of $60,000. The revenue agent has

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The IRS examines the 20X5 tax return of Sam Short. His return reported tax due in the amount of $60,000. The revenue agent has determined that Sam understated his tax for 20X5 by $22,000 and is proposing to assess the substantial understatement penalty. What arguments might Sam make that the IRS should not assess the penalty?

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