$47.$ A taxpayer can also avoid a penalty under Section $6694$ if:

A$.$ if the position is frivolous and disclosed on the tax return.

B$.$ if the position has a realistic possibility of being sustained by the IRS or courts.

C$.$ if the position is not frivolous and disclosed on the tax return.

D$.$ if the position has a reasonable basis and is disclosed on the tax return.

E$.$ None of the choices are correct.