Advanced

Technical position paper with uncertainty and FIN 48-style support

Drafts a technical position paper including uncertainty assessment and documentation to support a position in provision/audit contexts. Useful for tax directors and auditors.

Draft a technical tax position paper suitable for provision/audit support.

Inputs:
- Tax position: {tax_position}
- Facts and assumptions: {facts_assumptions}
- Authorities and interpretations: {authorities}
- Potential IRS/authority challenge points: {challenge_points}
- Quantification of exposure (if known): {exposure_quantification}

Output:
1) Position summary and basis.
2) Technical analysis with pros/cons and uncertainty points.
3) Suggested documentation and controls to support position.
4) Measurement considerations (range, sensitivity) if quantified.
5) Draft disclosure considerations (if applicable).

Be explicit about uncertainties; avoid overconfidence.

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