does anyone know if there is a way to search the forum for a specific MCQ? I'm hoping maybe somebody else ran into this question and I can find my answer there.
I'm looking at Question #: 21 Category: 1A1 Treasury Department Circular 230
A CPA assists a taxpayer in tax planning regarding a transaction that meets the definition of a tax shelter as defined in the Internal Revenue Code. Under the AICPA Statements on Standards for Tax Services (SSTS), the CPA should inform the taxpayer of the penalty risks unless the transaction, at the minimum, meets which of the following standards for being sustained if challenged?
A. More likely than not
B. Not frivolous
C. Realistic possibility
D. Substantial authority
I picked D, but according to the explanation: “More likely than not†is now the standard for judging the chances of a position being accepted by the IRS and the courts. “More likely than not†can also be stated as “better than one chance out of two.â€
Say what? I went back to my review material and it definitely says substantial authority. So then I actually looked up the SSTS and Regulations – Regulations say “substantial authority” and SSTS “realistic possibility” – do I just not know how to read?
WHAT IS HAPPENING?
any help?