Houston Has Found Conflicting Authorities That Address a Research Question

question 46

Essay

Houston has found conflicting authorities that address a research question for one of his clients. The majority of the authorities provide a favorable answer for his client. Nonetheless, there are several authorities that provide an unfavorable answer. Houston estimates that if the client takes the more favorable position on its tax return there is approximately a 60 percent chance that the position will be sustained upon audit or judicial proceeding. If the client takes this position on its tax return, will Houston be subject to penalty? Will the client potentially be subject to penalty?

---

Definitions:

Gluteus Maximus

The largest and most superficial of the three gluteal muscles, responsible for the shape of the buttocks and movement of the hip and thigh.

Biceps Femoris

A muscle of the thigh that is part of the hamstrings, involved in knee flexion and thigh extension.

Quadriceps Group

A muscle group located in the front of the thigh, consisting of four muscles that extend the knee and provide leg extension.

Biceps Femoris

A muscle of the thigh located at the back of the leg, part of the hamstring group, involved in knee flexion and hip extension.