Chang wants to claim a cost recovery deduction for the acquisition of original artwork to be hung in the reception area of her dental office. The paintings were specially chosen because of their tendency to relax the patients who would be viewing them, thereby facilitating the conduct of Chang's business. Chang lives and works in the Fifth Circuit. A recent Eleventh Circuit case seems to support such a deduction, in limited circumstances. Complete the following chart, indicating for each independent assumption the actions that Chang can take without incurring the civil penalty for substantial understatement of taxes, but still maximizing her legitimate deductions for the year.

Write a client letter that outlines the sources of authority that support (or oppose) your conclusions.

Probability of Success in Court           Claim the Deduction?             File a Form 8275 Disclosure?

80%

40%

20%

2%