Abstract The article presents a discussion of contextual factors on IRS agents' assessments of taxpayer negligence. In the paper, researcher Michael L. Roberts investigates the relationship between IRS revenue agents' decisions to impose the negligence penalty and four factors: education level of the taxpayer, size of the audit adjustment, the number of years in which problems occurred; and presence or absence of a CPA representing taxpayers. Based on culpability theory, Roberts predicts that the greater the number and severity of the factors indicating the taxpayer is at fault, the more likely the revenue agent is to assess the negligence penalty. Results indicate that size of audit adjustment, number of years in which problems occurred and taxpayer's education level affect revenue agents' decisions to assess the negligence penalty, while presence or absence of a CPA representing the taxpayer does not affect agents' decisions. The conference discussion of the paper focused on four topics: contribution of the paper to the tax literature, culpability theory, the effect of the issue choice on results; and suggestions for future research. The discussion is organized around these topics.
Anne L. Christensen (Sat,) studied this question.