A tax practitioner is researching a client’s specific busine…
A tax practitioner is researching a client’s specific business deduction. The practitioner finds that the Internal Revenue Code is silent on the specific detail, but they locate a U.S. Tax Court decision generally supports the taxpayer’s treatment of the item. If the weight of this supporting authority provides approximately a 40% chance of the position being sustained upon audit, how should the practitioner advise the client regarding the 20% accuracy-related penalty?