A Taxpayer Can Avoid a Substantial Understatement of Tax Penalty

A taxpayer can avoid a substantial understatement of tax penalty:

A) if the position is frivolous and disclosed on the tax return.
B) if the position has a realistic possibility of being sustained by the IRS or courts.
C) if there is substantial authority to support the position.
D) if the position has a reasonable basis and is not disclosed on the tax return.
E) None of the above.