Latrelle prepares the tax return for Whitehall Corporation. Latrelle includes a $5,000 deduction on the return. This type of deduction previously has been disallowed by the Tax Court, although there is a 15% chance that the holding will be reversed on an appeal. The return does not make any special disclosure that the deduction is being claimed. Whitehall paid Latrelle a fee of $3,000 for preparing the Form 1120. Latrelle will be assessed a preparer penalty of $1,000 for taking an unreasonable position on the Whitehall return.
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