AICPA SSTS#1 requires that a client's tax return position:

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AICPA SSTS#1 requires that a client's tax return position have a realistic possibility of being sustained if challenged by the Treasury or in the courts. This means that the position must be based on reasonable interpretation of the tax law and supported by relevant facts and circumstances. Substantial authority and conformity with IRS interpretations are not necessarily required, although they may bolster the position's credibility. The prior year's return is also not a relevant factor in determining the sustainability of the current year's position.

AICPA SSTS#1 Requires That a Client's Tax Return Position