Navigating the Gray: Planning vs. Evasion
AICPA SSTS and Circular 230 anchor positions to substantial authority or realistic possibility thresholds, supported by disclosure when appropriate. I once lost an argument on technical grounds but avoided penalties because the analysis was balanced and thoroughly documented. Standards illuminate difficult choices.
Navigating the Gray: Planning vs. Evasion
Declining a questionable position is hard, especially under pressure. I refused to sign a return with backdated documents; weeks later, the client returned, thankful we had protected their reputation. Saying no can nurture trust, even when it first appears to jeopardize the relationship.