[Anonymous]

Can anyone provide more clarity on the appropriate standard for judging the chances of a position being accepted by the IRS?

Originally, I thought a CPA could only recommend a tax position that had a “realistic possibility” (a.k.a. “the position will more likely than not be upheld” or 1/3 probability of success). However, I have seen other literature stating that “more likely than not” is now the new standard (a.k.a. “better than one chance out of two”).