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When is a tax return position with a reasonable basis level of confidence unlikely to result in a penalty? - no penalty should be asserted
When is a tax return position with a reasonable basis level of confidence unlikely to result in a penalty?
- no penalty should be asserted
- the taxpayer performed inadequate due diligence before taking the position
- the position was disclosed on either Form 8275 or Form Form 8275-R
- there was a valid business purpose for the transaction related to the position
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