Experts' perceptions of substantial authority

Abstract

The substantial understatement penalty dramatically changed the rules of the tax "lottery", and significantly altered the role of CPAs in the tax return preparation process. One way to avoid this penalty is to prove that substantial authority exists for the position taken on the tax return. Because it is relatively new, substantial authority has no judicial or official administrative interpretation. The main objective of this study was to explore the underlying dimensions used in making a substantial authority determination. As substantial authority has not been defined, this study was an initial effort at constructing an operational definition of substantial authority. The multidimensional scaling analysis in this dissertation suggests that certain authorities are perceived to possess certain distinct characteristics. The subjects clearly perceived some authorities as providing greater authority both quantitatively and qualitatively than others.