Sonja 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. Sonja asks you for advice. If she follows the treaty position, does she need to disclose this on her tax return? If she is required to disclose, are there any penalties for failure to disclose? Prepare a letter in which you respond to Sonja. Tile’s address is 100 International Drive, Tampa, FL 33620.