Chapter 17, Problem 2BCC

Basis for Conclusions Case 2: Uncertain Tax Positions and Examination Risk²⁶

26Repnnted from the Ernst & Young Academic Resource Center with permission of the Ernst & Young Foundation. Copy right 2014. All rights reserved.

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Current guidance on uncertain tax positions requires that when an entity is making its assessment as to whether a tax position is more likely than not to be sustained, it must assume that the position will be examined by the relevant taxing authority and that the taxing authority has all the relevant knowledge and information (FASB ASC 740-10-25-6 and FASB ASC 740-10-25-7). There is some controversy over this decision Read paragraphs B17 through B22 in the BCs in FASB's Interpretation No 48.

What are the arguments of the opponents of this rule?

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What are the arguments of the proponents of this rule?

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Which position do you support? Explain