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What is an unreasonable position on a tax return? What is the standard to determine if a position is unreasonable?

What is an unreasonable position on a tax return?

What is the standard to determine if a position is unreasonable?

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Answer #1
An unreasonable position is when, while evaluating or taking a call / position, professional judgement would dictate that it is not accurate and it will affect tax liability in a substantial manner
A position is generally unreasonable when there is no substantial support about it in the tax laws. Unless there is a reasonable basis for a position, it is UNREASONABLE even if there are adequate explantions about it in the return filed by the assessee.
In case of tax shelter, if it DOES NOT meet the criteria of more likely than not standard, than it is UNREASONABLE.

If challenged by the IRS and the probability of it being sustained is more than 50% then it is REASONABLE.

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