In the course of researching whether a particular tax position of your tax client satisfies the realistic possibility of success standard, you discover that another taxpayer took the same position on a tax return several years ago and that the return was audited by the IRS. You discover that the IRS agent who conducted the audit was aware of the position and decided the treatment on the return was correct. The revenue agent's report, however, made no mention of the position.

Do you believe the determination by the revenue agent provides sufficient authority for purposes of the realistic possibility of success standard with respect to your client's tax position? Explain why or why not, in light of SSTS No. 1. Assume you adopt that position, what should your tax client do as a result and why?