Choice "B" is correct. For an opinion to be a covered opinion, the opinion's evaluation of significant federal tax issues cannot take into account the possibility that (1) a tax return will not be audited, (2) an issue will not be raised on audit, or (3) an issue, if raised, will be resolved through settlement. The evaluation must be based on the chances of success on the merits, not on these other factors.Choice "d" is incorrect. For an opinion to be a covered opinion, the opinion must reach an overall conclusion as to the likelihood of the tax treatment for each significant tax issue and provide the reasons for this conclusion or state that the practitioner is unable to reach an overall conclusion (and provide the reasons for the inability to reach a conclusion).Choice "a" is incorrect. For an opinion to be a covered opinion, the opinion must set forth the likelihood that the taxpayer will prevail on the merits for each significant federal tax issue. If the likelihood cannot be determined for a particular tax issue, the opinion can still be issued but must state that fact. Choice "c" is incorrect. For an opinion to be a covered opinion, the opinion cannot be based on unreasonable factual assumptions, factual representations, or statements or findings of the taxpayer or any other person. An unreasonable factual representation is a factual representation that the practitioner knows or should have known is incorrect or incomplete.