FIN 48 provides that a tax position must be recognized when it has a "more-likely-than-not" probability of being sustained on examination. In this analysis,the statutes of limitation should be considered.

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In determining the probability of a position being sustained on examination,the statutes of limitation should be taken into account. For example,a tax position which originally does not satisfy the "more-likely-than-not" threshold would satisfy the threshold when the statutes of limitation expire with respect to the return for which the position was claimed.

FIN 48 Provides That a Tax Position Must Be Recognized