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To avoid the tax preparer penalty for understatement of the tax liability in an undisclosed position, the taxpayer's position on the return must, at a

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To avoid the tax preparer penalty for understatement of the tax liability in an undisclosed position, the taxpayer's position on the return must, at a minimum have a realistic possibility of success. not be frivolous. have substantial authority. be more likely than not (more than 50% chance) to succeed. have a reasonable basis

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