SEE-3 - Representation before the IRS - Section 2.3

Identify and weight sources of tax authority - the Code, regulations, rulings, and case law - and apply the substantial authority and reasonable basis standards to support a position.

Rank the sources of federal tax authority from the Internal Revenue Code and Treasury Regulations through revenue rulings, revenue procedures, and case law, distinguishing primary authority from secondary sources such as IRS publications. Apply the disclosure-and-penalty standards a position must meet - more likely than not, substantial authority, and reasonable basis with adequate disclosure on Form 8275 - to avoid accuracy-related and preparer penalties.

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