Reg Sec 11

Question 1

More likely than not
Substantial authority
Realistic possibility
Reasonable basis

Answer 1

when a position has a better than 50% probability of being sustained

substantial authority for a position that has approximately a 40% probability of being sustained.

There is a realistic possibility of success when a position has approximately a 1/3 probability of being sustained.

Reasonble basis for the position that has approximately a 20% probability of being sustained

Question 2

Audit periods

Answer 2

Under SOX 1 annual audit period must be completed before member of audit team my accept employment as principle officer of an audit client.

Question 3

Tax Return(Confidential)
Contingent  fee

Answer 3

not permitted to use it for personal benefit or reveal this info to third parties without consent. Exceptions are: valid government order, as part of qulity control peer review program

Practitioner my charge a fee when claim refund in connection with statutory interest or penalties charged by the IRS.