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B is corrent because the standards state that a position for which there is a reasonable basis may be recommended so long as the position is adequately disclosed on the return or claim for refund.
A is incorrect because a position taken by a CPA must have at least a realistic possibility of success.
C is incorrect because unless the taxpayer is bound to a specified treatment in the later year, the treatment of an item as part of concluding an administrative proceeding does not restrict the CPA from recommending a different tax treatment in a later year’s return, when circumstances may differ.
D is incorrect because a CPA is not to recommend a position that serves as a mere "arguing" position.