Area 1

Question 1

Tax Position Explanation

Answer 1

Frivolous Position Less than a 20% probability of being sustained on its merits

Reasonable Basis At least a 20% probability of being sustained on its merits

Realistic Possibility Requires a 33.33% likelihood of success

Substantial Authority Requires a 40% likelihood of success

More likely than not Requires a more than 50% probability of being sustained on its merits

Question 2

How are Bankruptcy Estates Distributed?

Answer 2

Priority (Secured & IRS) Claims first

Timely Filed Unsecured Claims

Remainder goes to not timely filed claims