JATA - Fall 1983

Volume 5, No. 1

Tax Court Classification of Activities Not Engaged in for Profit: Some Empirical Evidence

Jack Robison


The results of this study are based on the analysis of 219 post-1954 Tax Court cases involving determination of whether activities are or are not engaged in for profit. Profit analysis was used to identify and estimate the relative importance of factors used by the Tax Court in deciding this issue. Five factors were found to be significant predictors: manner of operation, level of expertise, time expended, history of income and loss, and the presence of elements of personal pleasure. Log-likelihood techniques were used to determine that the factors used by the Tax Court were not significantly altered by the passage of Section 183 and were stable across lines of "business."

The Analysis of Tax Court Decisions That Assess the Profit Motive of Farming-Oriented Operations

Jane O. Burns and S. Michael Groomer


This study employs multiple discriminant analysis to investigate Tax Court decisions that examine whether farming activities are pursued with an intent to make a profit. The population of 151 cases heard in the Tax Court through 1980 was used to develop linear discriminant models for three separate time periods. A number of techniques not previously used in studies of this nature were employed to comprehend more fully the nature of judicial decision-making in this area. The results indicate that some shift in the variables considered important by the judiciary took place over time. In recent years, the Tax Court has begun emphasizing a number of variables specified within the regulations.

The Certification of Tax Specialists: Some Empirical Results

C. Douglass Izard and John D. McKinney


The certification of specialists in accounting has developed into a controversial topic. This study was based on a questionnaire survey of 274 southeastern accountants and their perceptions and attitudes about the certification of tax specialists. The analysis considered a comparison among the three groups sampled and the aggregate sample through the use of chi-square analyses. The results indicate possible support for a special certification of tax specialists as well as indications of certification requirements and post-certification requirements. The over-all results have important implications for the development of an acceptable tax specialists' certification program.

Doctoral Program with a Concentration in Taxation: An Examination of Recent Trends

Richard Boley and Edmund Outslay


There has been a considerable increase in the number of persons enrolled in and graduating from doctoral programs with a concentration in taxation. This article analyzes that growth and provides a profile of the doctoral programs of twenty-seven schools that identified themselves as offering such a program. The information and related observations provided in this article are intended to aid prospective doctoral students in identifying potential schools for their studies and to aid tax educators in recommending (or designing) doctoral programs in taxation.

A Letter From Our President

Jenny Brown
ATA Section President

Greetings ATA Members and Colleagues,                             

Welcome to the 2023/2024 academic year!

First, thank you for giving me the opportunity to serve as your president this year. The ATA is an extraordinarily collegial group, and I feel privileged that it has been a significant part of my professional life since I was a PhD student at the University of Texas, 20-plus years ago. Over the years, I have seen the ATA change and evolve to better meet the needs of its members, but one thing remains the same ­– the ATA continues to be my primary professional home outside my own university. 


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