Concept · C:more-likely-than-not-tax-position-recognition

More-likely-than-not tax-position recognition

Working definition

The Topic 740 recognition threshold applied to whether a tax position is expected to be sustained on its technical merits under the required examination assumption.

Recognition asks whether a tax position is more likely than not to be sustained on its technical merits under the required examination assumptions. Complete this gate before measuring the amount of benefit. A high expected dollar recovery or favorable settlement offer does not replace the recognition analysis.

Keep recognition before measurement

ASC 740-10-25-6 sets the more-likely-than-not technical-merits threshold. The conclusion assumes examination with relevant information under the related guidance.

A supplied legal memo may conclude that a research credit position passes recognition. Only then does the accounting schedule apply the cumulative-probability measurement rule to supported settlement outcomes. If recognition fails, the model does not select a smaller weighted benefit as a compromise. Record unit of account, relevant law, reporting date, examination assumptions, memo owner, and conclusion. The course applies a supplied conclusion; it does not provide tax or legal advice.

Reassess the conclusion when dated facts change; do not carry last year's memo forward merely because the return position remains open.

Learning objectives

Put the concept to work

Learning level

Analyze this concept

  • Apply a supplied technical-merits recognition conclusion before measuring any benefit and preserve the examination assumption.

Learning resources

Choose a lesson, try an application, or inspect the sources behind this concept.

Updated Sep 11, 2026 Review due Nov 8, 2026