Key Takeaways

  • Must have reasonable basis for positions taken on returns.
  • Undisclosed positions require "substantial authority" standard.
  • Disclosed positions require only "reasonable basis" standard.
  • Must inform clients of potential penalties for positions.
  • Must advise of disclosure opportunities to avoid penalties.
  • Frivolous positions are disreputable conduct.
Last updated: January 2026

Tax Return Positions (Section 10.34)

Why This Matters for the Exam

Position standards determine when you can ethically take a position on a return. The exam tests whether you understand the difference between disclosed and undisclosed positions and the applicable standards.

Expect at least 3-4 questions on position standards and penalty disclosure.

The Position Standards Hierarchy

Tax return positions must meet certain confidence thresholds:

StandardConfidence LevelWhen Required
Reasonable basis~20% chance of successDisclosed positions
Substantial authority~40% chance of successUndisclosed positions
More likely than not>50% chance of successTax shelter positions

Disclosed vs. Undisclosed Positions

Position TypeStandard RequiredDisclosure Form
DisclosedReasonable basisForm 8275 or 8275-R
UndisclosedSubstantial authorityNo disclosure

Key Point: Disclosure allows you to take a position with a lower confidence level because you're alerting the IRS to the issue.

Penalty Disclosure Duties

Practitioners must inform clients about:

DutyDescription
Potential penaltiesWhat penalties may apply if position is disallowed
Disclosure opportunitiesHow disclosure can reduce penalty risk
Documentation optionsWhat records should be maintained

Reasonable Basis vs. Substantial Authority

FactorReasonable BasisSubstantial Authority
Confidence~20%~40%
Frivolous?No (must be beyond frivolous)No
Technical supportAt least one authorityMultiple authorities
When usedDisclosed positionsUndisclosed positions

Frivolous Positions

A frivolous position is one with no colorable basis in law—it's patently improper.

Examples of Frivolous Positions:

  • "Wages are not income."
  • "Filing returns is voluntary."
  • "The IRS is unconstitutional."

Consequence: Taking a frivolous position is disreputable conduct under Section 10.51.

Continuing Representation

If a client takes a position the practitioner believes is improper:

  • Practitioner must explain how to correct noncompliance.
  • Consider whether continuing representation is appropriate.
  • Cannot sign a return containing a frivolous position.

Real-World Scenario

Scenario: A client wants to claim a home office deduction. You research and find it's a close call—maybe 30% chance of prevailing if challenged.

  • Undisclosed: Does not meet substantial authority (~40%). Cannot claim without disclosure.
  • Disclosed: Meets reasonable basis (~20%). Can claim with Form 8275 disclosure.
  • Your duty: Inform client of penalty risk and disclosure option.

On the Exam

Expect 3-4 questions on positions, typically:

  1. Standard Questions: "What standard applies to undisclosed positions?"
  2. Disclosure Questions: "What form is used to disclose return positions?"
  3. Frivolous Questions: "Which position is considered frivolous?"
  4. Penalty Disclosure Questions: "What must practitioners inform clients about?"

The key is to remember: Undisclosed = substantial authority. Disclosed = reasonable basis. Frivolous = disreputable conduct.

Test Your Knowledge

What standard applies to undisclosed tax return positions?

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B
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D
Test Your Knowledge

What must practitioners inform clients about regarding return positions?

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B
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D
Test Your Knowledge

Which form is used to disclose a return position to the IRS?

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B
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D