R5 - Ethics and Professional Responsibilities in Tax Services Flashcards

1
Q

Under Circular 230, a covered opinion:

A

Arises from a transaction that, at the time the tax advice is rendered, the IRS has determined it to be a tax avoidance transaction and identified as such in IRS-published guidance.

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2
Q

The negligence penalty with respect to understatement of tax is:

A

An accuracy-based penalty for negligence or for disregard of tax rules and regulations.

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3
Q

Reasonable basis standard:

A

Is a position that has at least a 20% chance of succeeding, on that is arguable but fairly unlikely to prevail in court.

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4
Q

Substantial Authority Standard

A

Is a position that has more than a one-in-three chance in succeeding, but less than a more-than-50-percent chance of succeeding (the “more likely than not” standard) >33% but <50%

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5
Q

More Likely than not standard

A

> 50%, a position that has more than a 50% chance of succeeding.

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6
Q

U.S. District Court Cases are heard before how many judges?

A

One Judge

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