Aposition will be reasonable if the position has even if it is not disclosed. 2. for tax shelters, a position is treated as unreasonable unless it is reasonable to believe that the position has of being sustained. 3. a return preparer may not adopt a position without for the position. 4. in order to avoid penalties with a disclosed position, the tax preparer must believe that the position has of being sustained. 5. omits information necessary to determine the taxpayer's tax liability or is based upon the taxpayer's desire to impede the collection of tax. 6. is a willful attempt to evade federal tax liability, even that of another person, and is subject to criminal penalties, including imprisonment.

Adog whistle manufacturer's factory was located near a residential area. the manufacturer used the most effective methods for testing its whistles, but it was impossible to completely soundproof the testing area. a breeder of champion show dogs bought some property near the factory and raised and trained her dogs there. although the whistles were too high-pitched to be perceived by human ears, they could be heard by the breeder's dogs. consequently, the dogs often were in a constant state of agitation. in a suit by the breeder against the manufacturer, what is the likely outcome? response - correct a the breeder will prevail on a trespass theory, because the sound waves are entering onto the breeder's property. b the breeder will prevail on a nuisance theory, because the sound of the whistles is a substantial interference with the breeder's use of her land. c the breeder will not prevail, because the sound of the whistles is not a substantial interference with the breeder's use of her land. d the breeder will not prevail, because the manufacturer has acted reasonably in testing its whistles.