Abstract Tax professionals collect, weigh, and combine information from various sources to formulate an evaluation of the level of authority for a given tax position. Because no explicit, objective guidelines exist for performing such an evaluation, there are no clear-cut "correct" answers available with which to compare individual professional judgments of most tax Issues. Until there are such guidelines, the ambiguity of tax authority judgments must be resolved through consensus, i.e., the degree to which tax professionals concur in their evaluations of tax authority. This research explores tax professionals' evaluations of the level of authority for generic tax situations involving "gray" areas, i.e., areas in which there exists support for and against a tax position. Judgments of 56 tax personnel from a Big Eight CPA firm concerning the level of authority for 130 context-free tax scenarios were analyzed. Results include (1) a rank-order analysis of the weightings of seven sources of authority allowed under Treasury Regulations, (2) judgment consensus analysis of the tax professionals' evaluations of the level of authority in a controlled experiment, and (3) consistency analysis to determine the stability of the tax professionals' judgments over time.
Bain et al. (Sat,) studied this question.