Step 4: Evaluate Authority

Regardless of whether a researcher is reading from a printed page or a computer screen, the researcher must have the skill to interpret and evaluate the authority at hand. In some cases, the authority may provide an unambiguous answer to the researcher’s question. In other cases, the answer may be equivocal because the authority is inconclusive or subject to interpretation. Or perhaps different sources of authority provide conflicting answers. In these cases, the researcher must bring his or her own judgment to bear in analyzing the authority and answering the question. 

Weighting Authorities

All tax authority does not carry the same precedential value. For example, the tax court could hold that an item should be excluded from gross income at the same time that an outstanding IRS Revenue Ruling asserts the item is taxable. The tax researcher must evaluate the two authorities and decide whether to recommend that his or her client report the disputed item.

How Research Can Loop

In the process of evaluating the authority for the issue(s) under research, new issues previously not considered by the researcher may come to light. If this is the case, the researcher may be required to gather additional facts, find additional pertinent authority, and evaluate the new issues. All of these research activities must be related to the client’s research problem. The researcher uses professional judgment in selecting issues and determining the effort to expend on the issues. This loop is illustrated below:

What do you want to do?

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