When to stop researching and call it a position, with substantial authority
Lesson 6 of 6 · Tax research that survives review
1 · Learn the move · Flipped interaction
Research can run forever, and a model will let it. The stopping rule is the standard the position has to meet, and the preparer knows it before the first prompt. For most return positions the preparer-penalty standard is substantial authority, with a lower standard where the position is disclosed; the standards and their definitions live in s. 6694 and its regulation, which you open and quote rather than remember [P]. Circular 230 adds the duty to exercise due diligence on what you sign [P]. So flip the interaction: instead of asking the model what the answer is, have it interview you. Which standard applies? What authority have you opened, with the date? Which propositions are SETTLED and which are not? What would an examiner cite against you? When the interview ends with the authority you have actually read supporting the position at the standard that applies, you stop. When it ends with a CONTESTED proposition the position depends on, you either disclose, or keep reading, or decline the position. The model asks; you answer; the decision is yours and so is the signature. Draft copy, not legal advice. Reviewed by: nobody yet.
Interview me before I call this a return position. Ask one question at a time and wait for my answer: (1) which standard applies to this position and where I read it [VERIFY s. 6694 and its regulation]; (2) each authority I have opened, with the date I read it; (3) for each proposition the position depends on, whether I label it SETTLED, CONTESTED or OPEN; (4) what an examiner would cite against the position; (5) whether disclosure changes the standard. After my answers, say only one of three things: 'the authority you have read supports stopping at the standard you named', 'the position depends on a non-SETTLED proposition; disclose, read further, or decline', or 'you have not named the standard'. Never tell me the answer to the tax question. Never say the position is approved.
2 · Your turn. You write the prompt
The partner has spent six hours on Taxpayer E's research credit position. She has the statute, the regulation and two cases open on her screen, dated. The staff memo depends on one proposition the two cases treat differently. The return is due in nine days and she wants to know whether to stop.
Write the prompt for this scenario as given, or swap in a real one from your own work. The score works the same either way.
Remember: the AI sees only your prompt, not this page. If the situation isn't in your prompt, it doesn't exist.
Optional. These shape the output when you run your prompt below, not your score.