If you are providing tax services to a client, can you:
1. Sign / submit a tax return that contains a tax position that is supportable by the available client provided information and has a realistic possibility of success? If so, what does that mean and what disclosures should be made in the tax return that is filed? If disclosure is required in the tax return that is filed, and the client refuses to provide that disclosure, what do you need to do?
2. Submit / file a tax return that contains a tax position that is more likely than not to be accepted by the tax authorities? If so, what does that mean and is any disclosure in the tax return required?
3. Should the tax professional allow him/herself to be engaged to do tax work when the sole purpose of the client engaging you is to avoid tax? If so, what should the tax professional do before accepting such an engagement, if anything?
4. If the work described above was accepted, would that tax professional be required to be registered to be allowed to represent the client's case before the Federal tax authority and in what circumstances? Can anyone represent taxpayers with the Federal Tax authorities? What if anything is required?