This subdivision provides an overview on the relevant literature on revenue enhancement equity perceptual experiences, revenue enhancement conformity and the determiners under probe.
2.1 Fairness in Taxation
Tax ( or willingness to pay revenue enhancements ) is a fairness issue because it involves an exchange procedure ; the single taxpayer wants to cognize what s/he receives in return for the revenue enhancements that s/he wages. However, equity is a multi-faceted concept and does non merely concern how social resources are distributed among citizens but besides how the outgo programme is constructed in footings of the distribution across different social domains. The distribution facet of equity, that is, the distributive justness is presumptively the dominant and most outstanding equity facet relevant to willingness to pay revenue enhancements.
In the field of revenue enhancement, the construct of revenue enhancement equity and equity is intertwined. Tax equity is subdivided into perpendicular equity and horizontal equity. While perpendicular equity is concerned with the attack of ‘ability to pay ‘ , significance, greater ability to pay involves greater sum of revenue enhancement to pay, horizontal equity provinces that taxpayers, who are in a similar state of affairs, should consequence payment of the same sums of revenue enhancements ( Musgrave & A ; Musgrave, 1989 ) . However, the construct of revenue enhancement equity supersedes that of revenue enhancement equity in the sense that it is a much broader construct and comprises many dimensions of equity as identified by revenue enhancement literature, which shall be discussed subsequently.
Although the most obvious intent of most revenue enhancements is to raise gross to finance public outgos, this is non the lone principle for revenue enhancement which may besides be employed to modulate societal and economic behavior and to determine the distribution of economic resources. For this ground, the construct of revenue enhancement equity is needfully pluralistic, depending on the peculiar intent for which the revenue enhancement is imposed. Not surprisingly, hence, modern public assistance provinces typically levy a mix of revenue enhancements, including personal and corporate income revenue enhancements, broad-based ingestion revenue enhancements, excise revenue enhancements on specific goods or services, paysheet revenue enhancements, belongings or wealth revenue enhancements, wealth transportation revenue enhancements, every bit good as user fees and benefit revenue enhancements.
Since the justification for any revenue enhancement presumptively depends on the legitimacy of the underlying intent which it is designed to advance, the construct of just revenue enhancement is needfully secondary and derivative – depending on more cardinal rules refering the equity or justness of the public disbursement that revenue enhancements finance, the regulative ends that they support, and the distribution of economic resources that they help to specify.
2.2 Dimensions of Tax Fairness
There is limited literature that observes how taxpayers evaluate a just revenue enhancement system. The literatures that do detect revenue enhancement equity found it hard to specify. Christensen et Al ( 1994 ) identifies four troubles in specifying revenue enhancement equity viz. : the multidimensionality of equity, 2 ) equity can be defined at two degrees: the person and societal, 3 ) the interconnectedness between equity and complexness and 4 ) the perceptual experience of the unfairness of a revenue enhancement may imply taxpayers towards non compliant behaviour. Consequently, many research workers ( e.g. Porcano, 1984 ; Richardson & A ; Sawyer, 2001 ; and Jackson & A ; Milliron, 1986 ) agree that revenue enhancement equity is a multidimensional construct.
Gerbing ‘s ( 1988 ) factor and point analysis of the revenue enhancement equity judgements identified four implicit in dimensions of equity: ( I ) general equity and distribution of the revenue enhancement load, ( two ) exchange with authorities, ( three ) attitude towards revenue enhancements of the wealthy, ( four ) preferred revenue enhancement rate construction and ( V ) ego involvement. This determination supports the place that equity is a multidimensional construct.
Surveies conducted by Christensen et al. , ( 1994 ) and Christensen and Weihrich ( 1996 ) besides documented the being of the 5 revenue enhancement equity dimensions similar to Gerbing ( 1988 ) utilizing the study instrument developed by Gerbing ( 1988 ) . Christensen et Al. ( 1996 ) made a farther probe and the same revenue enhancement equity dimensions were found. Harmonizing to them, three standards derived from literature based on ‘social justness ‘ , can be used as a step of revenue enhancement equity: equity ( whether an person ‘s inputs are relative to his/her results ) , equality ( whether everyone is treated every bit ) and need ( whether there should be particular commissariats ) .
Another survey that had used the instrument developed by Gerbing was conducted by Richardson ( 2006 ) and Giligan & A ; Richardson ( 2005 ) . These surveies were administered in Hong Kong. Richardson ( 2006 ) and Giligan & A ; Richardson ( 2005 ) found that despite cultural differences that exist in Hong Kong and other western states, similar revenue enhancement equity dimensions were found in Hong Kong. Additionally, he identified a 6th revenue enhancement equity dimension which is in-between income earners, which is a dimension unique to Hong Kong.
Etzioni ( 1986 ) underlines the multidimensionality and interdisciplinary of revenue enhancement equity in his survey since he identified that the facet of carnival could hold been defined either from an economic sciences or ethical position. This means either from the position of acquiring just benefits for revenue enhancements paid or from the thought that the revenue enhancements are merely and just. Dimensions of equity used by Maroney et Al ( 2002 ) were exchange equity, horizontal equity, and perpendicular equity. Porcano ( 1990 ) made usage of a set of nine factors to mensurate revenue enhancement equity and it was targeted to revenue enhancement professionals.
Figure 1: 5 Tax Fairness Dimensions
2.3 Measures of Tax Fairness
It is by and large accepted that equity relates to the grade to which the rules of horizontal and perpendicular equity are achieved by the revenue enhancement system ( Plimmer et al. , 2000b ) .
The perpendicular equity asserts that taxpayers with different economic state of affairss should be taxed at different rates ( Erich et al. , 2006 ) . This would ensue in higher income earners paying revenue enhancement at higher rates than low-income earners. Vertical equity is assessed based on the ability to pay and preference for revenue enhancement rate construction, either level rate or imperfect. Another constituent is horizontal equity, defined as ‘the equal intervention of every bit circumstanced persons ‘ ( Michael, 1978 ) . In other words, horizontal equity recommends that taxpayers of similar economic places should pay the same sum of revenue enhancement.
These two dimensions of equity are derived from the Distributive Justice Theory ( DJT ) which asserts that for a system to be perceived as carnival, it needs to handle people in similar fortunes in tantamount mode, without pretermiting the persons ‘ demands. In other words, the theory is proposing that a via media has to be made between these dimensions of equity to carry through positive perceptual experiences on the equity of an income revenue enhancement system.
Other dimensions of fairness include a penchant for either progressive or relative revenue enhancement ( Turman, 1995 ) , personal equity, revenue enhancement rate equity, particular commissariats and general equity ( Gilligan & A ; Richardson, 2005 ; Richardson, 2005a ; Christensen & A ; Weichrich, 1996 ; Christensen et al. , 1994 ; Gerbing, 1988 ) .
2.3.1 Equity Theory
Tax equity is classically related with equity theory. First proposed by Adams ( 1963 ) , Equity theory provinces that people make comparing of the ratio of their attempt put with that of their benefits reaped and finally with the same ratios of others. If there is an inequality in the ratios, this may imply some problems, ensuing into a feeling of guiltiness and choler to those taxpayers having comparatively more end products and those having comparatively less outputs severally. Two specific issues are addressed by the Equity theory viz. : the perceptual experience to be just and the action of people following their perceptual experience of equity.
Equity theory has besides been expanded to include the procedural justness and the distributive justness. Therefore, procedural justness combined with distributive justness is perceived as societal justness by some research workers such as Christensen & A ; Weihrich ( 1996 ) while Leventhal ( 1980 ) saw the two types of justness as features that are considered by persons when doing judgements about equity. Nevertheless, the Equity theory has been criticized by Porcano ( 1984 ) since he saw that the construction of the distributive justness theory was much sophisticated than that of the equity theory.
2.3.2
Distributive justness Theory
In the revenue enhancement context, distributive justness refers to the rule that everyone pays his just portion of revenue enhancement without it being overstated or understated.
Distributive justness refers to the sensed equity of the concluding form or result of a resource allotment event, ( e.g. , a revenue enhancement outgo programme ) and is typically evaluated with regard to the equity of those outcome distributions ( Adams 1965 ; Deutsch 1985 ; Homans 1961 ) . As mentioned earlier, Distributive justness theory incorporates the equity, equality and demand regulations for specifying revenue enhancement equity. The conceptual differentiations underlying those three regulations help us in depicting the revenue enhancement system from a distributive equity position.
As such, Distributive justness in the revenue enhancement sphere is normally explored in relation to conformity ( Bobek & A ; Hatfield 2001 ) . It has a important function in the procedure of revenue enhancement conformity ( Tyler, 1997 ; Wenzel, 2003 ) . However, the results of distributive justness on conformity tend to change inconsistently, while some surveies have shown positive impact, others have no impact at all.
2.4 Tax Conformity
Tax conformity is a complex term to specify. Harmonizing to Brown and Mazur ( 2003 ) , revenue enhancement conformity is multi-faceted step and theoretically, it can be defined by sing three distinguishable types of conformity such as payment conformity, registering conformity, and describing conformity. The definition given by Alm ( 1991 ) revolves around the revelation of all incomes and payment of all revenue enhancements by adhering to the statutory commissariats, regulations and ordinances while that of Singh ( 2003 ) pertains to a individual ‘s voluntary conformity and proper declaration of emoluments within the clip frame set without holding to be warned by revenue enhancement governments.
Theoretically, positions of the taxpayers and revenue enhancement aggregators are that revenue enhancement conformity means adhering to the revenue enhancement Torahs, which are different from one state to another. The end of revenue enhancement disposal is to promote voluntary revenue enhancement conformity ( Silvani, 1992 ) and therefore cut down revenue enhancement spread[ 1 ]. Tax conformity, harmonizing to Cobham ( 2005 ) , is a job to many states as measured by revenue enhancement to GDP ratio although it has been bettering for many states. For illustration, its tierce of GDP in rich states ; Latin America and the Caribbean – 17 % of GDP and low-income states ( in Sub Saharan Africa ) showed less than 15 % to GDP ( the recommended rate ) . It remains a large challenge to low income states. This has promoted extremist revenue enhancement reforms in states like Bolivia, Uruguay, Colombia, Jamaica and Spain with noteworthy success ( Bird & A ; De Jantscher, 1992 ) .
2.5 Tax Conformity Literature
The mystifier of the economic theory of revenue enhancement conformity is why people pay revenue enhancements. Harmonizing to Allingham and Sandmo ( 1972 ) , based on Becker ‘s ( 1968 ) economic theory of offense, the extent of disincentive, as the merchandise of the chance of being detected and the size of the mulct imposed, determines the sum of income revenue enhancement evaded. Similarly, it is of primary concern to turn to the argument as to whether revenue enhancement conformity consequences from reduced revenue enhancement rates and economic inducements as many economic experts claim or from other factors as good, specifically taxpayers ‘ perceptual experiences that revenue enhancements are just.
In relation to revenue enhancement, taxpayers ‘ attitudes may be defined as positive or negative positions of revenue enhancement conformity behavior. The result of positive positions is revenue enhancement conformity and negative positions are revenue enhancement non conformity. These positions may be explained by Psychology-based theories which reveal that taxpayers ‘ attitude may be influenced by the undermentioned factors which finally influence taxpayers ‘ behaviour.
Roth et Al. ( 1989 ) and Yankelovich et Al. ( 1984 ) found important support for the dealingss between perceptual experiences of equity and conformity, exchange equity and conformity, and besides conformity and committedness when tested for revenue enhancement disobedience utilizing constructs such as revenue enhancement underreporting and dishonesty.
Jackson and Milliron ( 1986 ) carry out a comprehensive reappraisal of the revenue enhancement conformity literature and place 14 cardinal factors that have been studied by research worker on revenue enhancement conformity. Fischer et Al. ( 1992 ) proposed a theoretical account of taxpayer conformity with four dimensions based on those 14 factors. The first 1 is the demographic dimension which includes age, gender and instruction of taxpayers. The 2nd dimension is the non-compliance chance which captures, income degree, income beginning and business of taxpayers. The 3rd one is the attitude and perceptual experiences dimension which covers taxpayers ‘ attitudes towards equity of revenue enhancement system and equal influence. The last dimension is the revenue enhancement system or construction which deals with complexness of the revenue enhancement system, contact with revenue enhancement governments, chance of sensing and punishments and revenue enhancement rates. Therefore Fisher theoretical account of revenue enhancement conformity incorporates economic, sociological and psychological factors into a comprehensive 1.
This theoretical account has been through empirical observation tested by Chan et Al. ( 2000 ) utilizing a structural equations approach with sample informations collected from taxpayers in Hong Kong and the USA. It was reported that there is no direct connexion between demographic factors like income degree, age and gender and revenue enhancement conformity.
There are, nevertheless, different research workers that have cited factors such as demographic, income, conformity cost, and revenue enhancement agents as holding an influence on revenue enhancement conformity ( Mohani, 2003 ) besides factors refering to moral or ethical.
Other research workers ( Sour, 2002 ; Keller, 1997 ; Trivedi, 1997 ; Hamm, 1995 ; Chang et al. , 1987 ) listed enforcement component factors like punishment, audit, and revenue enhancement rates as holding a great influence on revenue enhancement conformity behavior. Tax conformity behavior of a taxpayer normally differ from the conformity behavior estimated in economic science theoretical accounts. Taxpayers are greatly influenced by other taxpayers. Besides, the rate and quality of audit will besides act upon revenue enhancement conformity behavior of a taxpayer ( Trivedi, 1997 ) .
Tax conformity has ever been an country of concern to the revenue enhancement decision makers and policy shapers. This is due to the fact that it affects gross aggregation every bit good as the ability of the authorities to accomplish its financial and societal ends ( Tan & A ; Sawyer, 2003 ) . However, revenue enhancement conformity research conducted so far is chiefly focused on developed states. In position of the insufficiencies in the institutional model and deficient expertness and resources to supervise the elaboratenesss of the revenue enhancement conformity jobs, developing states are peculiarly vulnerable to revenue enhancement disobedience. There is an pressing demand for more empirical and institutional research on the revenue enhancement conformity behaviours in developing states.
2.6 Explaining Tax Non-Compliance: Disincentive or attitudes?
In explicating taxpayers ‘ conformity behavior, that is, the grounds why taxpayers comply and do non follow, there are loosely two categories of theories – economic based theories, which emphasize inducements, and psychology-based theories which emphasize attitude ( Trivedi & A ; Shehata, 2005 ) .
2.6.1 Deterrence Theory
The ground behind non conformity of taxpayers ‘ towards their revenue enhancement duties is of peculiar concern to most gross governments around the universe. Harmonizing to the some of the early research based on the scrutiny of the revenue enhancement conformity behavior and taxpayers ‘ leaning towards revenue enhancement equivocation or turning away, the usage of a disincentive theory model was much favoured ( Jackson & A ; Milliron, 1986 ; Roth, Scholz & A ; Witte, 1989 ) .
Disincentive theories are rooted in economic sciences and portray people as ‘amoral profit-seekers whose actions are motivated entirely by rational computation of costs and chances ‘ ( Kagan & A ; Scholz, 1984, p. 69 ; Kirchler & A ; Maciejovsky, 2001 ) . Harmonizing to the disincentive position, people carefully assess chances and hazards, and disobey the jurisprudence when the anticipated mulct and chance of being caught are little in relation to the net incomes to be made through non-compliance ( Kagan & A ; Scholz, 1984 ) . Carroll ( 1987, 1992 ) argued that the disincentive theory is consistent with the classical expected public-service corporation theory and hence taxpayers are expected to do conformity determinations to maximise their public-service corporations. Under expected public-service corporation theory, taxpayers are viewed as a public-service corporation maximising single who choose to hedge revenue enhancement whenever the expected addition exceeds the cost ( Allingham & A ; Sadmo, 1972 ) .
The Deterrence Theory chiefly emphasizes employment of menace, coercion, and extrinsic stuff inducements. Harmonizing to this line of thought, the tools that the revenue enhancement bureau can utilize to modulate citizen behaviour are revenue enhancement rates, perceived chance of sensing in instance of equivocation, legal effects, and badness of these legal effects. However, a system that is mostly based on surveillance and countenances is likely to be excessively dearly-won. Furthermore, it does non ever ensue in observing equivocation and may, in add-on, produce psychological reactance. Therefore, such a system may take to opposite and relatiative behaviors, if it is perceived as bastard ( Brehm & A ; Brehm, 1981 ) .
The economic disincentive theoretical account of revenue enhancement conformity introduced by Becker in 1968 has from thereon, been adopted by about all economic attacks to revenue enhancement conformity and there have been some of import empirical surveies on the likely effects of disincentive on conformity viz. : Williams and Hawkins ( 1986 ) , Fisher, Wartwick, & A ; Mark ( 1992 ) , Hasseldine ( 2000 ) , Torgler ( 2002 ) and late Kirchler ( 2007 ) . Decision reached from analysis, demonstrate that both the likeliness of being detected and the sternness of countenances by and large have undistinguished positive consequence on conformity.
2.6.2 Psychology Theory
Given the fact that the Deterrence research undertaken in the context of revenue enhancement has reported uninterrupted inconsistent consequences, many revenue enhancement research workers have questioned the disincentive theory model as the most appropriate theoretical account for explicating taxpayer behavior. These research workers, alternatively, suggest that taxpayer attitudes towards the revenue enhancement system and paying revenue enhancement demand to be incorporated into theoretical histories of non-compliance. The findings of surveies conducted about attitudes toward, and beliefs about, revenue enhancement and its equivocation suggest that taxpayer attitudes towards the revenue enhancement system, and the manner taxpayers feel treated by a revenue enhancement authorization are of import in explicating taxpayer non-compliance.
Alternatively of concentrating on the job of revenue enhancement non-compliance, modern societal and behavioural scientific theorizing stresses the function of norms, trust, justness, and morality in heightening revenue enhancement conformity which is a more positive focal point ( e.g. , Cullis & A ; Lewis, 1997 ; Falkinger, 1995 ; Kinsey, Grasmick, & A ; Smith, 1991 ; Scholz & A ; Lubell, 1998 ; Wenzel, 2002 ) .
In general, harmonizing to this line of research, there is an alternate attack, called the attitudinal or intrinsic attack to revenue enhancement conformity and revenue enhancement equivocation. Tax remunerators are viewed as ‘voluntarily ‘ following with their revenue enhancement responsibilities as a map of intrinsic motive, i.e. , internalized norms of behavior ( e.g. , reciprocality – taxpayers behave reasonably toward the system if they are treated reasonably ) . ‘Voluntarily ‘ in this context means that the citizens pay revenue enhancements without surveillance or menace of countenances. Perceived equity of the revenue enhancement system is assumed to play a paramount function in bring forthing echt credence of revenue enhancement duties and ordinances.
Psychology theories of revenue enhancement conformity assume that psychological factors – including moral and ethical concerns are besides of import to taxpayers and so taxpayers may follow even where the hazard of audit is low. Psychology theories de-emphasize audits and punishments and alternatively concentrate on altering single attitudes towards revenue enhancement system. Trivedi and Shehata ( 2005 ) concluded that some taxpayers ‘ behavior may follow economic theories while others may follow the psychological theories and a mixture of the two is besides possible. Graetz and Wilde ( 1986 ) noted that conformity can non be explained wholly by the economic sciences factors. The writers argue that the persons ‘ behaviours and psychological factors may hold a important impact on taxpayers ‘ conformity behaviours. Behavioral attack assumes that persons are non merely independent, selfish public-service corporation maximisers but they interact harmonizing to differing attitudes, beliefs, norms and functions ( Elffers, 1991 ) . Surveies from the behavioral position suggest that demographic factors, such as age, gender, ethnicity and instruction ( Hasseldine and Hite 2003 ; Hite 1997 ; Rothengatter 2005 ) , and societal norms such as sensed equity, equal influence, moralss and revenue enhancement morale ( Alm, Sanchez, and Juan 1995 ) have a important consequence on revenue enhancement conformity.
2.7 Relationship between revenue enhancement equity perceptual experiences and revenue enhancement conformity
Numerous surveies have been published on the relationship between revenue enhancement equity perceptual experiences and revenue enhancement conformity. Tax research has documented that there is a nexus between perceptual experiences of revenue enhancement equity and conformity. Specifically, several analysts have pointed out the likeliness of the taxpayers following with the revenue enhancement proviso if there is a belief that the latter is just.
Christensen et Al ( 1994 ) has compiled literature that had observed the association between revenue enhancement equity and revenue enhancement conformity. The literature showed inconsistent findings. Likewise, literature such as Vogel ( 1974 ) and Porcano ( 1988 ) found no relationship between revenue enhancement equity and revenue enhancement equivocation.
Other surveies ( as reviewed by Richardson and Sawyer 2001 ) have explored the relationship between taxpayers ‘ perceptual experiences of equity and their conformity, with inconclusive consequences. Some of which they attribute to uncertainness as a consequence of the multidimensional nature of equity as a conformity variable. Conversely, they suggest that whether or non perceptual experiences of fairness influence compliant behavior, it is preferred for taxpayers to hold a favorable perceptual experience of the equity of the revenue enhancement system.
However, surveies such as Spicer ( 1974 ) and Hite & A ; Roberts ( 1992 ) found that revenue enhancement equity is associated with revenue enhancement equivocation. Surveies conducted by Scott and Grasmick ( 1982 ) and Spicer and Lundstedt ( 1976 ) indicate that respondents who believe that the revenue enhancement system is unjust are more likely to perpetrate revenue enhancement disobedience behaviour.
Survey informations from 1960-1980 by Etzioni ( 1986 ) documented that the fairness perceptual experience was more likely to impact revenue enhancement conformity instead than revenue enhancement rates. Turman ( 1995 ) and Roth et Al. ( 1989 ) confirmed that equity perceptual experiences influence revenue enhancement conformity behavior. Similarly, Porcano and Price ( 1992 ) , Harris ( 1989 ) , and Song and Yarbrough ( 1978 ) found revenue enhancement conformity to be significantly associated with perceptual experiences of an improved revenue enhancement system.
In his survey, Richardson ( 2006 ) found that all of Gerbing ‘s five dimensions of revenue enhancement equity exist in Hong Kong. However, his findings showed that self involvement and particular commissariats for the affluent were two dimensions that had the lowest significance. One possible ground was due to the cultural differences on the individuality, Bolshevism and power distance dimensions between Hong Kong and the US.
The recent cross-cultural survey by Gilligan & A ; Richardson ( 2005 ) observed the revenue enhancement equity dimensions between two culturally different legal powers, Australia and Hong Kong and reported that revenue enhancement equity perceptual experiences about general equity had a important impact on revenue enhancement conformity behavior in both states. It was besides found that no cosmopolitan forms exist cross culturally between revenue enhancement equity dimensions and revenue enhancement conformity behaviour.
With regard to the revenue enhancement system itself, there is peculiar support to propose that perceptual experiences of unjust revenue enhancement loads can impact taxpayers ‘ positions about paying revenue enhancement and can travel on to impact their conformity determinations. Harmonizing to Betty Jackson and Valerie Milliron ( 1986 ) , revenue enhancement equity seems to embrace at least two different dimensions. The first concerns the benefits that a taxpayer receives for the sum of revenue enhancement paid. The 2nd dimension involves the sensed equity of the taxpayer ‘s load in mention to that of other persons which is related to taxpayers ‘ perceptual experiences of the perpendicular equity of the revenue enhancement system. Hence, if compared to the sum paid by more affluent taxpayers, one is paying more than his just portion of revenue enhancement ( that is, sensed perpendicular inequality ) , the latter is more likely to see paying revenue enhancement as a load than a taxpayer non confronted with such an issue.
Similarly, in an experimental survey, Spicer and Becker ( 1980 ) found that the participants involved, increased the sum of revenue enhancements evaded when they perceived themselves to be the victims of perpendicular unfairness. Kinsey and Grasmick ( 1993 ) confirmed such statement when they found that alterations in attitudes towards revenue enhancement cheating were due in portion to perceptual experiences of increased perpendicular inequality in the US revenue enhancement system over clip.
A recent survey by Loo et Al. ( 2007 ) besides emphasized that attitudes towards the revenue enhancement system positively influenced conformity behaviour since a positive attitude towards the revenue enhancement system is in fact the consequence of positive equity perceptual experiences. Therefore, it was anticipated in this survey, that taxpayers with positive perceptual experiences on the equity of the revenue enhancement system are more likely to hold positive attitudes towards the revenue enhancement system and accordingly be encouraged to follow.
Research into procedural justness has besides shown that taxpayers demonstrate a more compliant behaviour when there is the grounds they have been treated impartially and considerately by a revenue enhancement authorization ( Wenzel, 2003 ) . An empirical illustration is that of a survey conducted in Swiss by Feld and Frey ( 2002 ) , where it is suggested that the revenue enhancement conformity increased when revenue enhancement governments treated taxpayers as trustworthy. What the findings presented in this subdivision suggest is that, taxpayers ‘ attitudes towards the revenue enhancement system, and how they feel they have been treated by a revenue enhancement authorization, do play an of import function in act uponing their determination to follow or non.
