Factors that Affect CPAs’ Personal Applications of Ethical Tax Standards to Ambiguous Positions

Abstract

This study examines how Certified Public Accountants (CPAs), as tax practitioners, interpret and apply the ethical tax standards established by the American Institute of Certified Public Accountants and the Internal Revenue Service (IRS), using a hypothetical situation. Although the authors attempt to determine if CPAs are more likely to apply the substantial authority standard given certain factors affecting both the CPAs and their tax clients, one-dimensional standard threshold applications leave us to interpret only whether these factors affect the CPAs’ decision to sign a tax return upholding an ambiguous position. The authors find that an aggressive CPA (self-reported) is more inclined to sign the return than an unaggressive CPA. The authors also find that favorable prior dealings with the IRS, and awareness that the IRS is not pursuing a contrary position to a certain tax position, both contribute significantly to the CPA’s willingness to sign the return. While an aggressive tax client also fosters willingness to sign, it appears that tax clients with a refund pending (as opposed to a payment pending) are more apt to trigger a signed return. Study results indicate that ambiguities in the tax code, in concert with mitigating CPA/client factors, may lead to significant discrepancies in interpretation and application.