check_authority
Classify each citation in a draft as authority or not under Treas. Reg. § 1.6662-4(d)(3)(iii) to flag penalty-protection problems, optionally checking the tax year.
Instructions
Classify a draft's citations as authority, or not, for penalty purposes.
Applies Treas. Reg. § 1.6662-4(d)(3)(iii), which lists what counts as authority for the substantial-authority standard under I.R.C. § 6662. Treatises, law review articles and practitioners' opinions are expressly not authority; a position resting on them has a penalty-protection problem. This classifies; it does not weigh.
Args: text: The draft to analyse. tax_year: Also check each authority against this tax year.
Input Schema
| Name | Required | Description | Default |
|---|---|---|---|
| text | Yes | ||
| tax_year | No |
Output Schema
| Name | Required | Description | Default |
|---|---|---|---|
| result | Yes |