Abstract

This study investigates whether Code section knowledge, which allows direct access to relevant authority, affects tax-research performance. This understanding is important because tax professionals are constantly searching the Code for relevant authority to resolve their clients' research questions, and because the Code is the ultimate source of tax authority. The research question is examined through an experiment that compares the research performance of experienced tax professionals and inexperienced graduate tax students when performing either a Code section or a topical search. The results indicate that experienced subjects are better able than inexperienced subjects to use Code section knowledge in tax research. In addition, the experienced subjects using the Code section method retrieved more relevant authority than any other group of subjects. Taken together, the results provide empirical evidence that Code section knowledge complements tax professionals' technical knowledge and improves tax-research performance.

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