6. What does the signing professional need before accepting a material position?

Why it matters: the owner should not discover a technical disagreement at filing time.

Good-answer framing: identify facts, authorities, contrary analysis, professional judgement, required disclosures where applicable and retained documentation. Explain how a disagreement is resolved and when independent counsel is appropriate; avoid promising that a memo eliminates examination risk.

Follow-up: “Who pays for additional review if the proposer and preparer disagree?”

Evidence request: a redacted issue-resolution process and engagement language, not privileged client material.

Expert quote: ____________________ Speaker/date/permission: ____________________