Aposition will be reasonable if the position has even if it is not disclosed. 2. for tax shelters, a position is treated as unreasonable unless it is reasonable to believe that the position has of being sustained. 3. a return preparer may not adopt a position without for the position. 4. in order to avoid penalties with a disclosed position, the tax preparer must believe that the position has of being sustained. 5. omits information necessary to determine the taxpayer's tax liability or is based upon the taxpayer's desire to impede the collection of tax. 6. is a willful attempt to evade federal tax liability, even that of another person, and is subject to criminal penalties, including imprisonment.