The "Reasonable Possibility of Success" Standard Commonly Is Associated with "1

The "reasonable possibility of success" standard commonly is associated with "1 out of 3" odds of success.These odds refer to the likelihood of success:

A) After the IRS has detected and challenged an asserted tax position
B) Taking into account the fact that the IRS may not detect a questionable tax position
C) Taking into account the fact that the IRS may detect a questionable tax position, but not challenge it due to limited government resources
D) Of the taxpayer achieving the beneficial tax savings desired from the asserted position