Unreasonable Position Definition | Becker
Accounting Dictionary
Unreasonable Position
A tax position is deemed unreasonable unless there is substantial authority for the position and the position does not involve either a tax shelter or a reportable transaction, or there is a reasonable basis for the position and the position does not involve either a tax shelter or a reportable transaction, or, with respect to a tax shelter or a reportable transaction, it is reasonable to believe that the position would more likely than not be sustained on its merits.