Substantial Authority Definition | Becker
Accounting Dictionary
Substantial Authority
Substantial authority is when the weight of an authority for the tax treatment of an item is substantial in relation to the weight of authorities supporting a contrary treatment. Authority includes the Internal Revenue Code and other statutory provisions, regulations, revenue rulings and revenue procedures, court cases, and other sources. Conclusions reached in treatises, legal periodicals, legal opinions, or opinions rendered by tax professionals are not authority.