Abstract This paper investigates the subjective judgments of IRS Revenue Agents about assessment of taxpayer negligence. Interviews with a designated IRS expert led to the development of a theory of taxpayer culpability based on circumstantial evidence. A series of 16 cases was developed involving variations of four factors that Culpability Theory and the IRS expert suggest might affect Revenue Agents' decisions to assess a negligence penalty. The four factors were: the education level of the taxpayer, the size of the audit adjustment, the number of years involved, and whether or not the taxpayer was represented by a CPA. One hundred Revenue Agents participated in the experiment. The results demonstrate the influence of three of the four hypothesized factors, and support the hypothesized interaction effect as well. In general, the size of the audit adjustment had the largest single impact on the decision to assess a negligence penalty and representation by a CPA had the least impact.
Michael L. Roberts (Sat,) studied this question.
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