A CTRS practitioner files a tax return taking an aggressive position without disclosing it. Under Circular 230, when is disclosure of a return position required?
-
A
Only when the position could result in a penalty exceeding $10,000
-
B
When the position does not have at least substantial authority supporting it
-
C
When the position involves a deduction for a business expense
-
D
Only when the IRS requests disclosure during an audit