Roger Prepared for Compensation a Federal Income Tax Return for Joan.Joan's

Roger prepared for compensation a Federal income tax return for Joan.Joan's return included an aggressive interpretation of the rules concerning overnight business travel.Roger is not liable for a preparer penalty for taking an unreasonable tax return position if:

A) There was substantial authority for Joan's interpretation of the travel deduction rules.
B) There was a reasonable basis for Joan's interpretation of the travel deduction rules.
C) The tax reduction attributable to the disputed deduction did not exceed $5,000.
D) The IRS found that the travel deduction was frivolous,but Joan disclosed the position in an attachment to the return.