How should the preparer advise the client to report

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Reference no: EM131989182

Problem

If a tax preparer is unable, after a reasonable amount of research and analysis to determine whether they believe a position attributable to a tax shelter item is more likely than not to be sustained on its merits, can they advise the taxpayer to take the position on the return without risking a penalty under IRC § 6694? If not, how should the preparer advise the client to report an item attributable to a tax shelter on the return and why?

Reference no: EM131989182

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