Personal integrity
Honesty and candor without personal gain or advantage
An innocent error or legitimate difference of opinion
Deceit or subordination of one’s principles
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Be purely personal in nature
Be subjective
Be described
Be prejudiced
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In a reasonable consideration, the position taken on the tax return could be sustained
Based upon industry standards, the deduction is sustainable
If a reasonable and well informed analysis of the law and the facts by a person knowledgeable in the tax law would lead such a person to conclude that the position has approximately a one in three, or greater, likelihood of being sustained on its merits
If a reasonable and well informed analysis of the law and the facts by a person knowledgeable in the tax law would lead such a person to conclude that the position would be sustained by an IRS revenue agent upon IRS examination
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Why the taxpayer should hire the tax professional
The relationship between the promoter and the practitioner
Any compensation agreement
Any referral agreement
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