R5 - Ethics and Professional Responsibilities in Tax Services Flashcards
Under Circular 230, a covered opinion:
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.
The negligence penalty with respect to understatement of tax is:
An accuracy-based penalty for negligence or for disregard of tax rules and regulations.
Reasonable basis standard:
Is a position that has at least a 20% chance of succeeding, on that is arguable but fairly unlikely to prevail in court.
Substantial Authority Standard
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%
More Likely than not standard
> 50%, a position that has more than a 50% chance of succeeding.
U.S. District Court Cases are heard before how many judges?
One Judge