A tax practitioner can avoid IRS penalty relating to a tax return position:

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According to IRS regulations, a tax practitioner can avoid IRS penalty if the position has a reasonable basis and is disclosed on the tax return. The reasonable basis standard is lower than the more likely than not standard required for individuals and businesses. However, it is higher than the realistic possibility standard. Additionally, substantial authority is another standard that a tax practitioner can use to avoid penalties, but it is usually used for more complex tax issues.

A Tax Practitioner Can Avoid IRS Penalty Relating to a Tax