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A Taxpayer Ordinarily Should Not Assert a Tax Position Unless

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A taxpayer ordinarily should not assert a tax position unless it is supported by a reasonable possibility of success." This standard commonly is referred to as requiring a certain probability of acceptance or approval if the position is detected and challenged by the taxing authority.What is the associated probability of success?


Definitions:

Consensus Theory

A sociological perspective suggesting that social order and stability are maintained through a general consensus on values, norms, and rules within society.

Punishment

The imposition of a penalty as retribution for an offense, often used within the context of criminal justice to deter unlawful behavior.

Rational Factors

Elements or considerations based on reason, logic, or facts that influence decisions or behaviors.

Hate Crimes

Criminal acts motivated by bias or prejudice towards particular groups, often defined by race, religion, sexual orientation, or ethnicity.

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