Butch Bishop operates a small international firm named Tile, Inc. A new treaty between the United States and Spain conflicts with a Section of the Internal Revenue Code. Butch asks you for advice. If he follows the treaty position, does he need to disclose this on this year’s tax return? If he is required to disclose, are there any penalties for failure to disclose? Prepare a letter in which you respond to Butch. Tile’s address is 100 International Drive, Tampa, FL 33620.