Task ID string | Question Type string | Prompt string | Reasoning Steps list | Ground Truth string | AI Check string | Sources and Material string | Prompt Feedback (1st Reviewer) string | Prompt Feedback (2nd Reviewer) string | Difficulty (1st Reviewer) string | Difficulty (2nd Reviewer) string | Reasoning Trace Assessment (1st Reviewer) string | Reasoning Trace Assessment (2nd Reviewer) string | Reasoning Trace Review (1st Reviewer) string | Reasoning Trace Review (2nd Reviewer) string | Difficulty Reasoning (1st Reviewer) string | Difficulty Reasoning (2nd Reviewer) string | Ground Truth Evaluation (1st Reviewer) string | Ground Truth Evaluation (2nd Reviewer) string | Review 1 - Ground Truth Examination string | Review 1 - Prompt Feedback string | Review 1 - Ground Truth Reasoning string | Review 1 - Difficulty string | Review 1 - Representativeness string | Review 1 - Reasoning Trace Justifications string | Review 1 - Difficulty Reasoning string | Review 1 - Representativeness Reasoning string | Review 2 - Ground Truth Examination string | Review 2 - Prompt Feedback string | Review 2 - Ground Truth Reasoning string | Review 2 - Difficulty string | Review 2 - Representativeness string | Review 2 - Reasoning Trace Justifications string | Review 2 - Difficulty Reasoning string | Review 2 - Representativeness Reasoning string | Review 3 - Ground Truth Examination string | Review 3 - Prompt Feedback string | Review 3 - Ground Truth Reasoning string | Review 3 - Difficulty string | Review 3 - Representativeness string | Review 3 - Reasoning Trace Justifications string | Review 3 - Difficulty Reasoning string | Review 3 - Representativeness Reasoning string | Review 4 - Ground Truth Examination string | Review 4 - Prompt Feedback string | Review 4 - Ground Truth Reasoning string | Review 4 - Difficulty string | Review 4 - Representativeness string | Review 4 - Reasoning Trace Justifications string | Review 4 - Difficulty Reasoning string | Review 4 - Representativeness Reasoning string | Review 5 - Ground Truth Examination string | Review 5 - Prompt Feedback string | Review 5 - Ground Truth Reasoning string | Review 5 - Difficulty string | Review 5 - Representativeness string | Review 5 - Reasoning Trace Justifications string | Review 5 - Difficulty Reasoning string | Review 5 - Representativeness Reasoning string |
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Tax Task #2 | Comparative Analysis | As a tax manager at a mid-size CPA firm, analyze the following situation and answer the questions that follow. Please give context and references. Your client is a multi-member LLC taxed as a partnership. For tax year 2026, they are selling their primary production facility in Pennsylvania and relocating to highly auto... | [
{
"step_id": "Step #1",
"reasoning_step": "Calculate the gains on each asset and determine the gains character (capital, ordinary, 1231, other recaptures)"
},
{
"step_id": "Step #2",
"reasoning_step": "Determine the amounts of realized gains and recognized gains if different. (option A, the reco... | The answer is option A. It creates the lowest amount of tax liability and the best net after-tax cash position. While the future depreciation will be worth less, the savings from the future depreciation do not offset the immediate costs and consequences. | Pass | IRC 1231, 1245, 1250 for depreciation recapture
IRC 1031 for the 1031 exchange
IRC 1031(b) for the boot
IRC 1031(d) for the basis in the new property
IRS Publication 544: Sales and Other Disposition of Assets https://www.irs.gov/publications/p544
IRs Publication 551: Basis of Assets https://www.irs.gov/publications/p... | the prompt is correct and well done. 1031 only on real property, machinery triggers 1245 ordinary gain 700k. net mortgage boot 3M - 2M + 1M. cash boot 1.5M from machinery. 1231 5 year loopback 155k prior losses will recharacterize 1231 gain as ordinary. current 1231 loss 45K. building 900k 1250 unrecaptured depreciatio... | Persona is identified. A lot of detail, but good context. Could simplify but the additional detail enhances the difficulty. Constraints are included and the task and output schema are clear. | Moderate | Hard | N/A | N/A | Yes | Yes | someone with 4 or more years should be able to handle this. they need a solid understanding of 1031, depreciation rules 1245/1250, 1231 netting and the 5 year recapture rule. proper distinction between real vs property properly. state tax conformity issues PA vs Fed. time value analysis NPV future depreciation at 7% di... | There is a lot of detail included, and some of the detail would likely trip up someone who is analyzing this. The tax professional would need a good understanding of various tax laws that are not necessarily encountered on a daily basis, depending upon what the individual's client base would be. | Correct | Correct | Incorrect | The prompt is a very strong will written prompt. It is clear and easy to follow. There are some areas for improvement. Clarify and unclear items regarding boot sources. Distinguish boot from 1031 exchange and taxable proceeds from non like kind assets. Specify tax rates in the areas of fed capital gain rates, ordinary ... | The Ground Truth (Option A) is not reliable because it skips key calculations and tax rules.
A proper analysis must apply Internal Revenue Code Section 1031, Internal Revenue Code Section 1231, and depreciation recapture under Internal Revenue Code Section 1245 and Internal Revenue Code Section 1250. | Hard | Typical | Step 1 - correct but too general. it should include IRC 1245, IRC 1250 and IRC 1231. Missing these reduces accuracy. Step 2 partially complete- debt relief = boot, machinery not eligible for 1031. Step 3 - incorrect - boot is generally allocated to realized gain, separate asset class matters. This step has technical m... | This is a complex item that requires advanced skill. | A typical task for a seasoned professional in a corporate tax dept. | Correct | Persona is clearly stated in the first sentence: "as a tax manager at a mid-size CPA firm."
Task and context are given right after in "answer the questions that follow. Please give context and references." After the facts are given, it says to "keep in mind recapture rules and the 5 year look back on section 1231 losse... | The answer about the Federal | Hard | Somewhat Typical | The reasoning trace tells you what steps are to be taken, but it does not perform the calculations or reference how it should be calculated. This step should effectively be performing these steps and walking you through the calculation.
Also, the prompt asks to compare the Pennsylvania treatment to the Federal treatme... | The background information that is provided gives you all the information that is needed to do the analysis. You need to have the deep domain-specific expertise in this area as not all tax professional are equipped to answer this question. You need to have complex reasoning to understand how each of the facts fits into... | These types are of transactions occur relatively frequently, but it is not an every day occurrence. | Correct | the prompt is correct and well done. 1031 only on real property, machinery triggers 1245 ordinary gain 700k. net mortgage boot 3M - 2M + 1M. cash boot 1.5M from machinery. 1231 5 year loopback 155k prior losses will recharacterize 1231 gain as ordinary. current 1231 loss 45K. building 900k 1250 unrecaptured depreciatio... | N/A | Moderate | Typical | N/A | someone with 4 or more years should be able to handle this. they need a solid understanding of 1031, depreciation rules 1245/1250, 1231 netting and the 5 year recapture rule. proper distinction between real vs property properly. state tax conformity issues PA vs Fed. time value analysis NPV future depreciation at 7% di... | typical scenario for a mid sized cpa firm | Correct | Persona is identified. A lot of detail, but good context. Could simplify but the additional detail enhances the difficulty. Constraints are included and the task and output schema are clear. | N/A | Hard | Somewhat Typical | N/A | There is a lot of detail included, and some of the detail would likely trip up someone who is analyzing this. The tax professional would need a good understanding of various tax laws that are not necessarily encountered on a daily basis, depending upon what the individual's client base would be. | Would be typical for some professionals, but uncommon for others so splitting the middle. | Incorrect | This is a very thorough fact pattern but likely tried to add too much information in the prompt and overlooked numerous details in order to try to make this more complicated, but this provides not enough clarity in the prompt and may lead to assumptions being made in order to answer the question, which may not provide ... | This is not an area that I deal with frequently, but I believe option B is the correct choice. Given the large amount of boot, I calculate that the gain, and then tax, is the same under either scenario, and thus the stepped-up basis of option B would be more beneficial than the carryover basis of option A. If the amo... | Very Hard | Typical | The reasoning steps are accurate, but it is coming to the opposite answer. | There is a lot of complexity here and asking for a technical memo of these facts and comparisons is not something a 4 year person would be able to do accurately. This would take some more oversight and assistance in identifying the assumptions and questions to ask to get to the right answer. | For a tax professional in general, doing this sort of comparison is a typical advisory service that would be requested from clients that are completing transactions. |
Tax Task #14 | Updates & Current Affairs | Company A is a U.S. c-corporation that engages vendors for R&D services both inside and outside of the U.S. The company incurred $100,000 of U.S. R&D expenses and $30,000 of foreign R&D expenses in 2023, $200,000 of U.S. R&D expenses and $60,000 of foreign R&D expenses in 2024, and $400,000 of U.S. R&D expenses and $1... | [
{
"step_id": "Step #1",
"reasoning_step": "Identify that the deductibility of R&D expenses is governed under IRC Sec. 174. For 2023 and 2024, the R&D costs must be capitalized and amortized over 5 years for domestic costs and 15 years for foreign costs. The amortization of these costs is under the mid-yea... | Company A has 3 options for its 2025 taxable income: continue to amortize its previously capitalized domestic Sec. 174 costs ($150,000 taxable income), elect to recover those previously unamortized costs over 2 years through transition rules under IRC Sec. 174A and Rev. Proc. 2025-28 ($85,000 of taxable income), or ele... | Pass | IRC Sec. 174 - https://www.law.cornell.edu/uscode/text/26/174
IRC Sec. 174A - https://www.law.cornell.edu/uscode/text/26/174A
OBBBA - https://www.congress.gov/119/bills/hr1/BILLS-119hr1eh.pdf
Rev. Proc. 2025-28 - https://www.irs.gov/pub/irs-drop/rp-25-28.pdf | Generally well constructed and reflects a corporate tax scenario involving sec 174 - capitalization and recent guidance. It is clear in its definition of entity type, gives a multi year R&D expense data and includes constraints that are applicable such as no prior sec 59e election and NOL carry forwards. determining 20... | No persona is given. Context and constraints seem reasonable. Task seems good quality. No output schema. | Hard | Moderate | Steps appear to focus on new 2025 expenditures but the core question is about previously capitalized unamortized costs. The reasoning must clearly distinguish pre 2025 capitalized amounts from new 2025 R&E. it should specifically list 3 transition options above and tie them to the facts. Cite OBBA PL 119-21, 70302 sec ... | N/A | No | Yes | This is complex and would require extensive experience by a senior level analyst. | While this task is math heavy, it only works on one knowledge set: that of R&D expenses. It does not add a complicating factor of another set of applicable rules or require a particularly difficult judgement call. | Correct | Correct | Correct | Generally well constructed and reflects a corporate tax scenario involving sec 174 - capitalization and recent guidance. It is clear in its definition of entity type, gives a multi year R&D expense data and includes constraints that are applicable such as no prior sec 59e election and NOL carry forwards. determining 20... | N/A | Hard | Somewhat Typical | Steps appear to focus on new 2025 expenditures but the core question is about previously capitalized unamortized costs. The reasoning must clearly distinguish pre 2025 capitalized amounts from new 2025 R&E. it should specifically list 3 transition options above and tie them to the facts. Cite OBBA PL 119-21, 70302 sec ... | This is complex and would require extensive experience by a senior level analyst. | Not a rare occurrence, but it does come up | Correct | No persona is given. Context and constraints seem reasonable. Task seems good quality. No output schema. | N/A | Moderate | Typical | N/A | While this task is math heavy, it only works on one knowledge set: that of R&D expenses. It does not add a complicating factor of another set of applicable rules or require a particularly difficult judgement call. | Helping a client decide on deduction/expense timing is a typical part of tax planning, even if the expenses are somewhat specialized or arcane | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
Tax Task #20 | Numerical Reasoning | You are a tax professional with 4 years of experience advising U.S. businesses. Company A is a U.S. c-corporation with 100% of its operations in Arizona. For its 2025 year, it has pre-tax book income of $100,000 which includes the following: $25,000 of meals expense, $10,000 of entertainment expenses, $50,000 of book ... | [
{
"step_id": "Step #1",
"reasoning_step": "Calculate tentative taxable income starting with PTBI ($100,000), adding 50% of the meals expense ($12,500), adding 100% of the entertainment expense ($10,000), adding book depreciation ($50,000), adding accrued bonus expenses ($30,000), and subtracting tax depreci... | (a) State Current Tax Expense = 100,000+12,500+10,000+30,000+(50,000-75,000) = $127,500 * 4.9% = $6,248
Federal Current Tax Expense = 127,500 (above) - $6,248 = $121,252 * 21% = $25,463
Total Current Tax Expense = $25,463 + $6,248 = $31,711.
(b) Federal Deferred Tax Expense = -50,000-30,000+75,000 = -5,000 * ... | Pass | IRC Sec. 274 (meals and entertainment expenses) - https://www.law.cornell.edu/uscode/text/26/274
IRC Sec. 167 (tax depreciation allowable) - https://www.law.cornell.edu/uscode/text/26/167
IRC Sec. 404 and 461 (accrued bonus) - https://www.law.cornell.edu/uscode/text/26/404 and https://www.law.cornell.edu/uscode/text/... | I feel like I have looked at this one before. I think it looks fine. | Persona is clearly stated. Context is given in that is a US corporation with 100% operations in AZ. Also, the facts are laid out. This is a straightforward tax provision calculation that needs to be performed. The constraints are clear which prevent any ambiguity. | Moderate | Moderate | N/A | N/A | Yes | Yes | mid range in difficulty. assign to a seasoned but not senior level | This requires domain-specific expertise of both corporate tax and ASC 740. It does not require reasoning as the calculations are black and white. No room for ambiguity. | Correct | Correct | Incorrect | The prompt does not provide a persona. It gives facts and asks for a solution. It does provide some context (i.e. US corporation in Arizona). Constraints are clear (ignore penalties and interest). The task is also clear, but it does not provide an output schema that should be used.
However, given the facts and constr... | N/A | Easy | Typical | N/A | This is a rudimentary example of ASC 740 given very basic facts. If you have any experience in tax provision work, this is as straightforward as it gets. | This is typical if you work in corporate tax and ASC 740. If you do not specifically do ASC 740, then that wouldn't necessarily be the case. | Incorrect | The prompt for this is mostly correct. The major issue is that the state current tax expense calculation starts with 100,000 + 12,500 + 10,000 + 50,000 + 30,000 - 75,000=127,500. This is incorrect. The correct pre tax book to taxable income adjustments for AZ would be Pre tax book income 100,000. Perm differences Meals... | N/A | Moderate | Typical | N/A | Moderately difficult as it involves lots of computations. | Typical for a company return. | Correct | I feel like I have looked at this one before. I think it looks fine. | N/A | Moderate | Somewhat Typical | N/A | mid range in difficulty. assign to a seasoned but not senior level | it comes up but is not an every day item. | Correct | Persona is clearly stated. Context is given in that is a US corporation with 100% operations in AZ. Also, the facts are laid out. This is a straightforward tax provision calculation that needs to be performed. The constraints are clear which prevent any ambiguity. | N/A | Moderate | Typical | N/A | This requires domain-specific expertise of both corporate tax and ASC 740. It does not require reasoning as the calculations are black and white. No room for ambiguity. | If you work in corporate tax and ASC 740, this is a regular activity that is performed. However, not all tax professional work in this area so that conclusion may differ across the industry. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
Tax Task #21 | Application & Compliance | Imagine you are a Manager of Tax with 7 years of experience advising United States corporations on federal income tax compliance and credit eligibility. CONTEXT - A US c-corp did significant R&D expenses during the current tax year and wants to evaluate whether it may claim the federal R&D tax credit on its return form... | [
{
"step_id": "Step #1",
"reasoning_step": "Identify applicable IRC provisions that govern the R&D credit. IRC 41 allows a credit for qualified research expenses incurred as part of qualified research activity conducted in the US. Since the company is a domestic c-corp, with US based R&D, the analysis shoul... | The company may claim $200,000 R&D credit in the current year based on IRC 41. The reason for this is that the company has incurred qualifying research activities. The credit is a general business credit under IRC 38. Since the company has positive taxable income, it is not subjected to AMT, has no applicable credit li... | Pass | IRC 41 - Credit for Increased Research Activities. IRC 38 - General Business Credit. Treasury Reg 1.41-4 Qualified Research Activities. IRS Form 6765 Instructions - Credit for Increasing Research Activity. | N/A | The persona is clear - you are a manager of tax with 7 years of experience.
The context gives you detail about the company and what leadership has tasked you with. The facts are clear.
Constraints are specifically laid out in which code sections to use. The task is asking whether the credit can be claimed and whether... | N/A | Moderate | N/A | N/A | N/A | Yes | N/A | You have to have domain specific expertise of how R&D tax credits are calculated. Calculating the credit under IRC Sec. 41 requires domain specific knowledge. | N/A | Correct | Correct | The prompt fails to provide the amount of taxable income the corporation has. This impacts whether the credit can be fully utilized during the year or if it is limited and needs to be carried forward. This information is necessary in order to answer one of the items (#3) requested in the output. Depending upon how th... | N/A | Easy | Typical | N/A | While the calculation of the R&D credit itself would be on the more difficult side, this prompt took out most of the complexity of that aspect. At its core, the prompt is only asking if the R&D credit can be claimed, which is a relatively easy question. Without taxable income or tax calculations, or without requiring... | For tax professionals, more clients than not will have some credit or deduction that is analyzed for realizability. While it may not be an R&D credit specifically, the analysis of a credit or deduction would be a typical task for a 4 year professional. If the prompt/task asked for more detailed analysis on the calcula... | Correct | The first sentence lays out the personal very clearly. The context is also clearly stated. After the facts are stated, there are constraints listed in that you should use Sec. 41 and 38 specifically. Output schema is in the last sentence as the prompt specifically states what the final product needs to be.
Overall, t... | N/A | Easy | Typical | N/A | Based on the details in the prompt, this is a very straightforward question. There weren't any details or nuances that required you to use a specific expertise or complex reasoning. | This is a high level analysis done for any corporation that conducts R&D activities. | Incorrect | Prompt includes all the appropriate requirements. The question is representative of the field and complex enough that a simple search wouldn't be able to answer it. The only concern is that there does not appear to be enough facts provided to answer all of the questions being asked (discussed below). | There are not enough facts provided to determine the amount of credit that can be utilized in the current year and if any needs to be carried forward to the following year. The facts do not specify the amount of taxable income the business has, which is needed. I do not understand why it is said that the credit is el... | Easy | Typical | N/A | This is a pretty easy task for an experienced tax manager given that most of the facts are provided and little research/determination is needed. | Calculating the availability and utilization of credits is typical in this profession. | Correct | The persona is clear - you are a manager of tax with 7 years of experience.
The context gives you detail about the company and what leadership has tasked you with. The facts are clear.
Constraints are specifically laid out in which code sections to use. The task is asking whether the credit can be claimed and whether... | N/A | Moderate | Somewhat Typical | N/A | You have to have domain specific expertise of how R&D tax credits are calculated. Calculating the credit under IRC Sec. 41 requires domain specific knowledge. | If you work with corporations, this is a somewhat typical scenario as many companies perform R&D activities. The question of whether they qualify and could benefit from the credit would require an analysis. | Correct | All 5 components of the task are there. The task is very typical of what tax accountants do for their clients. It is not answerable by a simple google search as it requires checking multiple limitations and rule sets | N/A | Moderate | Typical | N/A | This task is moderate difficulty because it requires some specialized knowledge and some professional judgment regarding taking the full credit or the reduced credit. | This task is very typical of tax accountants as determining the amount of credit eligible and the way to claim it are required tasks for preparing the entities returns, estimates, and provisions. |
Tax Task #22 | Semantic Analysis | Imagine you are a senior tax manager at a multinational company with significant US and worldwide operations. You have over 8 years of experience advising on fed income tax issues. this includes corporate restructures, intercompany, and tax accounting positions that are subject to Internal Revenue Service examinations.... | [
{
"step_id": "Step #1",
"reasoning_step": "Identify the applicable statutory provision that governs cancellation of indebtedness income. IRC 61(a)(12) includes income from the dischaging of indebtedness in gross income that will suggest that any elimination of a debt obligation must be evaluated for potenti... | The deemed satisfaction of intercompany debt in a 332 liquidation scenario will result in taxable cancellation of indebtedness income to the parent corporation under IRC 61(a)(12) because the cancelling of the debt constitutes a discharge and IRC 332 does not provide an specific exclusion for income that is realized fr... | Pass | IRC 61(a)(12), Treasury Regulation 1.61-12(a), IRC 332, US v. Kirby Lumber company 284 US 1 (1931) | The persona is very clear at the beginning. The context is well laid out given all of the facts and certain code sections that are being referenced. The constraints provide a clear indication of where this analysis should focus in the given context. The fact that it specifically says not to focus IRS guidance or taxpay... | Clear persona, context, constraints, task, and output. This is clearly a tax professional item and the output would not be able to be found through a simple search.
The only issue I have with this is that the question/answer is very ambiguous, and there is not a clear answer. While I can follow the reasoning, positi... | Very Hard | Very Hard | N/A | N/A | Yes | Yes | This is a very complex issue and requires both a senior-level expertise and judgment. There is some interpretation of the various regulatory guidelines that is requires as it's not just a black and white issue. | Even for a typical tax senior manager, this would be a very difficult task that requires significant judgement in analysis and would solicit feedback from other professionals. Tax directors and VPs of tax with this question/fact pattern would almost certainly seek the advice of a public accounting tax partner or tax l... | Correct | Correct | Correct | The persona is very clear at the beginning. The context is well laid out given all of the facts and certain code sections that are being referenced. The constraints provide a clear indication of where this analysis should focus in the given context. The fact that it specifically says not to focus IRS guidance or taxpay... | N/A | Very Hard | Rarely Encountered | N/A | This is a very complex issue and requires both a senior-level expertise and judgment. There is some interpretation of the various regulatory guidelines that is requires as it's not just a black and white issue. | The is a very specific issue with a lot of nuance. You may see a situation like this every few years, but most tax professional would almost never see this type of issue. | Correct | Clear persona, context, constraints, task, and output. This is clearly a tax professional item and the output would not be able to be found through a simple search.
The only issue I have with this is that the question/answer is very ambiguous, and there is not a clear answer. While I can follow the reasoning, positi... | N/A | Very Hard | Somewhat Typical | N/A | Even for a typical tax senior manager, this would be a very difficult task that requires significant judgement in analysis and would solicit feedback from other professionals. Tax directors and VPs of tax with this question/fact pattern would almost certainly seek the advice of a public accounting tax partner or tax l... | I would call this somewhat typical because of the persona that was outlined in the prompt. For a typical tax professional, this would be very uncommon/rarely encountered until they are much farther in their careers and/or employed by sophisticated global companies, which is a minority of the universe of tax profession... | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
Tax Task #28 | Problem Solving & Critical Thinking | Partnership P owns corporation C. Both parties are US companies with no foreign ownership. When P acquired the stock from C's owners, a loan document from P to C was executed creating a loan agreement with principal of $10,000,000 and annual interest of 10%. Any unpaid interest would accrue to the principal of the loan... | [
{
"step_id": "Step #1",
"reasoning_step": "The first step is to understand what the correct tax treatment would be for the interest income for P and the interest expense was for C. It's important to make the distinction between what the correct tax treatment regardless for how it had been treated on P's and... | To summarize the above, the correct treatment for P and C would have been to include interest as income and deduction, respectively in the years in which it accrued, regardless of whether it was paid. However, because no interest was actually paid, Sec. 108(e)(2) allows for the forgiveness of the interest component wit... | Pass | IRC Sec. 163(a), 267(a)(2), 108(e)(2), 108(e)(6), 118 | Strengths include - good persona. clear context and facts (partnership, ownership, loan terms, PIK interest, accrual method, no payments made, intent to unwind via contribution or capital contributions). Well defined Task with two specific questions. Output expectation is implicit correct annual treatment + analysis of... | N/A | Moderate | N/A | The reasoning is actually Yes, but I put no because I do not see a way to add notes to the steps. The ground truth correctly states that both P and C should have accrued interest income/expense annually under their accrual method, and sec 108e2 protects the interest component from COD income upon contribution. The over... | N/A | No | N/A | This does require some advanced knowledge and skill but can be done by a mid level employee. It falls squarely in the moderate range. | N/A | Correct | N/A | Correct | Strengths include - good persona. clear context and facts (partnership, ownership, loan terms, PIK interest, accrual method, no payments made, intent to unwind via contribution or capital contributions). Well defined Task with two specific questions. Output expectation is implicit correct annual treatment + analysis of... | N/A | Moderate | Uncommon | The reasoning is actually Yes, but I put no because I do not see a way to add notes to the steps. The ground truth correctly states that both P and C should have accrued interest income/expense annually under their accrual method, and sec 108e2 protects the interest component from COD income upon contribution. The over... | This does require some advanced knowledge and skill but can be done by a mid level employee. It falls squarely in the moderate range. | This is not a core activity that occurs regularly. It would be an uncommon however moderately difficult piece of tax to work on. | Incorrect | The prompt has personal, context, task and output. | Should clarify in the prompt that no additional share are being issued in the loan conversion as this is govern in different code section. Indicate if the adjusted issue price of the debt is greater than C’s adjusted basis because the difference must be recognized by C as CODI. Need to cite code section why P should r... | Moderate | Somewhat Typical | The sentences in each step got cut off in my view. Since the prompt is missing few facts that can generate a different treatment. It's better to add those in the steps. | There are quite a few facts need to gather to apply correct code section as there are many subsection under code 108, one fact can provide a different answer. For example, the basis in the debt. | Conversion of debt to capital contribution is common transaction many companies since the subsidiaries prefer to use the profit for investment rather than pay back to the parents | Correct | Persona, Context, constraints, task are all good. No output schema however. It is definitely the type of task accountants would be tasked with working on though not a regularly occurring one. The question seems fairly technical and specific and would probably not be easily found through a google search | N/A | Hard | Somewhat Typical | N/A | This requires some very specific and deep knowledge of particular tax rules as well as general IRS treatment of the unpaid interest in this fairly specific scenario. | I say this because while this is they type of task CPAs and tax accountants would be tasked with, its not the kind of problem many (or even most) CPAs will deal with. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
Tax Task #29 | Semantic Analysis | Corporate A acquired 100% stock of Corporate B in the fourth quarter of 2025 via a reverse triangular merger effectuated through Acquisition Sub, Inc., a transitory subsidiary formed solely for purposes of the merger, which merged with and into Corporate B, with Corporate B surviving as a wholly owned subsidiary of Cor... | [
{
"step_id": "Step #1",
"reasoning_step": " Given the transaction is non-taxable transaction, the facilitative transaction cost is required to capitalize under section 263."
},
{
"step_id": "Step #2",
"reasoning_step": "Because the transaction cost is not success-based fee; Corp A can't elect to... | Under Reg. § 1.263(a)-5(g)(2)(i), facilitative cost is required to be capitalized and added to the basis of the acquired stock (if the transaction is treated as an acquisition of stock for federal income tax purposes). Assuming the transaction cost is not success-based fee; Corp A need to capitalize $2,000,000 and the ... | Pass | Rev-Ruling 2011-29
Reg. § 1.263(a)-5(g)(2)(i)
| prompt quality is strong. it includes a clear context with reverse merger details, 100% stock acquisition in q4 2025 with no 338 election, task and output expectations. it is representative of corporate tax M&A work and it is still complex enough to require specific knowledge rather than doing a simple search of the it... | There is no persona here. The context is clear in laying out the facts. The fact that no 338 election has been made is a constraint. Same for the facilitative transaction costs and that the $2M was incurred after the brightline date.
The task and output are given in the last sentence.
This is representative of the f... | Moderate | Hard | N/A | N/A | Yes | Yes | requires solid knowledge of corporate tax rules, m&a statutes regarding transaction costs and reg 1.263a-5. A junior level professional with 1-2 years of experience should be able to handle. | Transaction cost analysis requires a deep subject matter expertise . There is complex reasoning needed. | Correct | Correct | Correct | The ground truth correctly applies reg 1.263a-5 which requires transaction costs in a stock acquisition to be capitalized rather than deducted. Since this is a 338 acquisition treated as a stock purchase for federal income tax purposes, the transaction costs are not deductible. Assuming the costs are not success based,... | N/A | Easy | Uncommon | the reasoning truth does lead to the ground truth answer, - however, the section above that says to provide feedback does not have an option to click on it and actually provide the feedback. So, I am putting feedback here. The steps are vague and incomplete. A strong reasoning trace should be clear, structured and logi... | This is something that an entry level tax staff can perform. It seems like there is not much subjectivity or decision making involved. | These situations do not occur regularly. However, it is still important and should be treated as such. | Correct | The prompt is missing the persona and output schema. The context might be missing some information as it's a very open ended prompt. Some more facts might be of use. The task would be clear if it gave more facts. Based on the facts provide, a better task would be to ask for a summary of what is needed to determine the ... | N/A | Moderate | Somewhat Typical | N/A | If you are advising on a transaction, you should be knowledgeable of this area and should have a good grasp of all the facts. You would need to exercise professional judgement when determine how to classify certain costs. | If you work in the transaction advisory space, these are relatively common questions. If you are a tax advisor who focuses more on compliance, this happens left often. | Correct | prompt quality is strong. it includes a clear context with reverse merger details, 100% stock acquisition in q4 2025 with no 338 election, task and output expectations. it is representative of corporate tax M&A work and it is still complex enough to require specific knowledge rather than doing a simple search of the it... | N/A | Moderate | Typical | N/A | requires solid knowledge of corporate tax rules, m&a statutes regarding transaction costs and reg 1.263a-5. A junior level professional with 1-2 years of experience should be able to handle. | regular work performed by tax professionals working in a corporate setting. | Correct | There is no persona here. The context is clear in laying out the facts. The fact that no 338 election has been made is a constraint. Same for the facilitative transaction costs and that the $2M was incurred after the brightline date.
The task and output are given in the last sentence.
This is representative of the f... | N/A | Hard | Uncommon | N/A | Transaction cost analysis requires a deep subject matter expertise . There is complex reasoning needed. | Transaction cost analysis comes mostly for M&A professionals. For core tax professionals, the is not a common occurrence. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
Tax Task #31 | Application & Compliance | Company A is planning to have a bonus plan for 10,000 in place for the first year and paid out in the following year. The company want to offset the income for bonus expense in the same year for tax purposes. The company is forecast to have a loss in the following year. Advise the company how to structure the the bonu... | [
{
"step_id": "Step #1",
"reasoning_step": "Accrued expenses are deductible if the liability is fixed and determinable at year end; which means all events test have met. For example, services are provided for liability at year end and amount is determinable."
},
{
"step_id": "Step #2",
"reasoning... | The 10,000 is deduct in the year when the liability is fixed and determinable which is year 1 if the company structure the bonus like the steps mentioned above. | Pass | Section 461 | There is no persona. Is this management of the company asking or are you a tax advisor advising the client?
The context is that the company wants payout a bonus and be able to deduct it in the year that it's accrued. (this isnt the most clearly written so it may give the LLM trouble in understanding.)
The fact that th... | No Persona, light context, no tax year, no constraint, no output schema. Task is very simple that could probably be google searched. | Trivial | Trivial | N/A | N/A | Yes | Yes | This is basic tax 101. A first year tax professional should be able to answer this in their first year. It does not require any judgement or specific expertise. | This is very basic accounting to tax knowledge about the timing of accrual based deductions | Correct | Correct | Correct | There is no persona. Who is asking and who is answering the question?
There is context as it gives specific dates and circumstances (board of director approval).
There isn't much in terms of constraint, but that may not be applicable.
The task is present as it's asking to determine the tax deductibility.
There is no ou... | N/A | Trivial | Core Activity | N/A | This is a basic tax 101 question. A first year tax professional should be able to answer this question. | These types of questions/issues comes up frequently in tax. It's an essential part of determining taxable income for a business entity. | Correct | no persona, little to no context, and no output schema. Constraints are minimal, task is very simple. | N/A | Trivial | Core Activity | N/A | This is basic knowledge any 1st year staff or even intern will learn right away when doing accrual-to-tax adjustments, which are common tasks for interns/1st years | very core activity for tax preparation. Knowing the timing of deductions and accrual-to-tax adjustments is a core knowledge for tax preparation. | Correct | There is no persona. Is this management of the company asking or are you a tax advisor advising the client?
The context is that the company wants payout a bonus and be able to deduct it in the year that it's accrued. (this isnt the most clearly written so it may give the LLM trouble in understanding.)
The fact that th... | N/A | Trivial | Core Activity | N/A | This is basic tax 101. A first year tax professional should be able to answer this in their first year. It does not require any judgement or specific expertise. | Calculating the deduction for accrued expenses is common practice for accrual basis taxpayers. This is a core knowledge that all tax advisors should know as most business entities may have book to tax differences for these items. | Correct | No Persona, light context, no tax year, no constraint, no output schema. Task is very simple that could probably be google searched. | N/A | Trivial | Core Activity | N/A | This is very basic accounting to tax knowledge about the timing of accrual based deductions | Understanding the timing of accrual based deductions for tax deductibility is a core skill for tax accounting. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
Tax Task #32 | Comparative Analysis | You are a U.S. tax professional. John, an individual, wants to open a new U.S. business. He believes the new business will create $100,000 of income each year. There will be no book/tax differences. John desires to distribute all of the money out of the business each year.
John's lawyers have advised him that a cor... | [
{
"step_id": "Step #1",
"reasoning_step": "Calculate the tax liability as an s-corporation. There is no tax liability at the entity level, and the entire $100,000 passes through to John. John's tax liability is: $100,000 * 28% = $28,000. "
},
{
"step_id": "Step #2",
"reasoning_step": "Calcula... | The s-corporation structure ($28,000) provides a lower overall tax liability than the c-corporation structure ($32,850). | Pass | IRC Sec. 11 - Corporate income tax rate: https://www.law.cornell.edu/uscode/text/26/11
All other information provided within the prompt. | no output schema. Very normal task for tax accountants and complex enough to avoid a simple google search. There is a flaw in the prompt: self-employment tax is often a very large part of the tax burden for people who are self-employed and should not be excluded form this task. You can't provide accurate or sound advic... | N/A | Easy | N/A | N/A | N/A | Yes | N/A | This is very simple task. Requires only basic knowledge of tax rules and fairly simple math | N/A | Correct | N/A | Correct | no output schema. Very normal task for tax accountants and complex enough to avoid a simple google search. There is a flaw in the prompt: self-employment tax is often a very large part of the tax burden for people who are self-employed and should not be excluded form this task. You can't provide accurate or sound advic... | N/A | Easy | Core Activity | N/A | This is very simple task. Requires only basic knowledge of tax rules and fairly simple math | This kind of analysis is very common for tax accountants and CPAs. People are always thinking about (or starting) small businesses and want an analysis on how the taxes will break down. | Incorrect | The persona and context are clear gin the first paragraph. The constraints are also clear in that John's lawyers advised that a corporation is best, the individual tax rate is 28%, and there are no state pr payroll taxes to consider. There are some additional facts that should be considered such as what tax year this i... | This is only part of the answer. The task asks to compare the overall tax liability under both structures, but the answer does not do that. It just says that S-Corppration is better. | Easy | Somewhat Typical | N/A | This is a very basic tax concept. It doesn't require complex reasoning or domain specific expertise. Any tax professional should be able to answer this. | Helping your clients select and entity type and what elections to make is a fairly common practice, but not an everyday occurance. | Correct | This is good for the details that are being asked. This question can easily be answered with a simple google search. | N/A | Trivial | Typical | N/A | very easy | something that will come up frequently. | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
Tax Task #34 | Problem Solving & Critical Thinking | Persona: You are a recent college graduate who just started your first full-time job and moved into your first apartment. Context: You earned a salary of $55,000 this year. You spent $1,200 on new professional work clothes, paid $3,000 in student loan interest, and donated $500 to a local animal shelter. You also spen... | [
{
"step_id": "Step #1",
"reasoning_step": "Determine the deductibility of the professional work clothes"
},
{
"step_id": "Step #2",
"reasoning_step": "Determine the deductibility of the student loan interest"
},
{
"step_id": "Step #3",
"reasoning_step": "Determine the deductibility o... | Work clothes are not deductible if they can be worn as normal clothes, so office or professional attire is generally not deductible
Student loan interest will be deductible at this income level. It is an above the line deduction
Charitable Donation should be deductible, presuming the shelter is a non-profit
Certificati... | Pass | IRS publication 17
IRS Topic No 456
IRC Section 221
IRS Publication 970
IRS Form 8863 Instructions
IRC Section 217
IRs Publication 526 | Persona is very clearly explained in the first sentence.
The context is clear and lays out all the facts.
The constraints tell you that you are single and what the standard deduction for 2025 is.
The Task is evident in that you are to evaluate which expenses are deductible, explain why, and determine whether to take ... | Accurate overall for 2025. work clothes are not deductible as they can be worn as normal clothes. student loan interest is deductible above the line with a 2500 max. with 55k salary, the taxpayer is well below the phaseout range of 85-100k for single filer. donation is deductible if a 503c3. the certification course i... | Easy | Easy | N/A | N/A | Yes | Yes | This is basic individual tax. The concepts are very straightforward and do not require any real reasoning. There is very little nuance as these are black and white issues. There is no judgement required. | easy - beginner staff can handle | Correct | Correct | Correct | Persona is very clearly explained in the first sentence.
The context is clear and lays out all the facts.
The constraints tell you that you are single and what the standard deduction for 2025 is.
The Task is evident in that you are to evaluate which expenses are deductible, explain why, and determine whether to take ... | N/A | Easy | Typical | N/A | This is basic individual tax. The concepts are very straightforward and do not require any real reasoning. There is very little nuance as these are black and white issues. There is no judgement required. | In cases where a tax practitioner works with individuals, determining whether to take the standard or itemized deduction is common practice. There are many instances where this is clear and you know right off the top of your head without any analysis (for example, nothing that would qualify as itemized deductions or co... | Correct | Accurate overall for 2025. work clothes are not deductible as they can be worn as normal clothes. student loan interest is deductible above the line with a 2500 max. with 55k salary, the taxpayer is well below the phaseout range of 85-100k for single filer. donation is deductible if a 503c3. the certification course i... | N/A | Easy | Core Activity | N/A | easy - beginner staff can handle | core activity for a tax preparer | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
Tax Task #35 | Semantic Analysis | A owns stock of B and C. A basis in both B and C is 1,000; the 1,000 basis in each include 250 of earning. At beginning of Yr2, Corp B merge into Corp C in a tax-free reorganization . At the time of the merger, value of B stock is 5,000. As result of the reorganization, A receive cash of 600. Calculate A basis in C ... | [
{
"step_id": "Step #1",
"reasoning_step": "Since this merger is intercompany transaction, Additional basis in C (fmv) is 5,000 with a basis of 1,000 under section 358 (a)(1)"
},
{
"step_id": "Step #2",
"reasoning_step": "Calculate the Corp C E&P: 500 (Corp B and Corp C) after the reorganization ... | A owns both B and C; the merger is treated as A receive additional basis in C of 5,000 with a basis of 1,000. The 600 cash distribution is considered as separate transaction, 500 is considered as dividend (up to earning and profit) and the remaining of 100 is return to capital where both reduce the A stock basis in C. ... | Pass | See sources and material in the steps | There is no persona still out output schema still. The context and task are clear.
This is a complex calculation and is representative of the field. | the prompt seems to be clear cut and the ask is thorough | Moderate | Easy | N/A | N/A | Yes | Yes | This calculation requires knowledge of various code sections and judgement in how to apply them. You need domain specific expertise to be able to calculate the answer. | Perfect calculation for an inexperienced 1-2 year staff member to handle | Correct | Correct | Correct | There is no persona here. Is this a tax professional advising a client? Is this leadership asking a junior professional?
There is context in the given facts.
There isn't much in terms of constraint, but that may not be applicable.
The task is clear.
There isn't an output schema. Are you looking for just a number, re... | N/A | Moderate | Somewhat Typical | N/A | You have to have experience in M&A transactions to be able to understand this issue and answer the question. You have to have a solid understanding of the facts and corporate tax knowledge. Not every tax professional would be able to answer this question without doing research or needing additional support. | This exact fact pattern isn't necessarily typical, but these types of questions do some up with some frequency. It's not core to the role unless you are an M&A tax professional. | Incorrect | No persona, no output schema. context is poor (no tax year given) very little constraints giving rise to some ambiguity. What type of tax-free merger? Task is simple. Not super-representative of the field as M&A acquisitions of this type are fairly arcane and often the realm of specialists. While the math may preclude ... | The FMV of B's stock has no bearing on the basis either before or after the merger. It can be a limiter on boot gained in the transaction but because the cash payout is so little, it has no effect. A's basis in C after the merger is $1,400 = $1,000 + $1,000 - $600. The part about $500 as dividend and $100 as return of ... | Trivial | Uncommon | N/A | While M&A rules can be difficult, this particular merger is not. This question would qualify as an exam question on the CPA exams or in college. Mechanics of calculating the answer are pretty easy to find via simple google search. | M&A of this type is a pretty specialized field and is rarely seen outside of those offices. | Correct | There is no persona still out output schema still. The context and task are clear.
This is a complex calculation and is representative of the field. | N/A | Moderate | Uncommon | N/A | This calculation requires knowledge of various code sections and judgement in how to apply them. You need domain specific expertise to be able to calculate the answer. | This is a very specific scenario. It does happen, but is not a common practice. | Correct | the prompt seems to be clear cut and the ask is thorough | N/A | Easy | Somewhat Typical | N/A | Perfect calculation for an inexperienced 1-2 year staff member to handle | it comes up but is not a regular course of action | Correct | the grammar on this is not great. some spelling and plural mistakes. the prompt is very short and vague in both its description and what it is asking. | N/A | Easy | Typical | N/A | when inputted correctly it is an easy task | nothing out of the ordinary |
Corp_Taxes — Expert-Authored US Corporate Tax Reasoning (Pilot Sample)
Seven evaluation tasks, authored and peer-reviewed by credentialed US corporate tax professionals.
Produced by Human Edge as a public demonstration of our expert-data methodology.
- Curated by: Human Edge
- Language: English
- License: CC BY 4.0
- Repository: HumanEdgeAI/Corp_Taxes
Why this dataset exists
Seven corporate tax scenarios, each written from scratch by a practicing US tax professional, paired with a ground-truth answer, a stepwise reasoning trace, and the statutory sources the expert relied on. Every task then passed through a review pipeline in which independent domain experts ruled on the answer's correctness, scored difficulty and real-world representativeness, and recorded written reasoning for both scores.
Frontier models handle textbook tax questions well. They are far less reliable on the multi-step, statute-dependent reasoning that practitioners do daily — where the answer turns on which provision governs, how basis and boot are allocated, and what the current-year rules actually say. Evaluating that requires people who do the work, not annotators following a rubric.
Why the review data is the point
Most public evaluation datasets ship a question and a gold answer. Whether qualified experts actually agreed on that answer, and on how hard the question is, is discarded.
This dataset keeps it. Every task carries its two final peer reviews in full — 14 reviews across 7 tasks — each with a ground-truth verdict, a difficulty score, a representativeness score, and the reviewer's written justification for each score.
These are the reviews that closed the task out, so all 14 affirm the ground truth. That unanimity is the output of the process rather than evidence that review was frictionless. Across the same seven tasks, four drew a ground-truth challenge at some point during review, four required a second full round after revision, and two required adjudication by a third expert. Those are overlapping but distinct groups of four — a challenge did not always trigger a second round, and a second round was not always preceded by a challenge. The superseded rounds are held internally; what ships here is the settled position and the reasoning behind it.
Where the two final reviewers still disagreed, both positions stand as recorded. They split on difficulty for 4 of 7 tasks and on representativeness for all 7.
Contents
| Tasks | 7 |
| Columns | 21 |
| Domain | US corporate tax |
| Final peer reviews | 14 (2 per task) |
| Tasks that required a second review round | 4 of 7 |
| Tasks that required adjudication | 2 of 7 |
| Reasoning steps | 34 across all tasks |
| Prompt length | 643–2,763 characters |
| Language | English |
Question types — six categories, each represented:
| Type | Tasks |
|---|---|
| Statutory Interpretation | 2 |
| Comparative Treatment | 1 |
| Rule Application | 1 |
| Multi-Issue Analysis | 1 |
| Numeric Reasoning | 1 |
| Recent Developments | 1 |
Difficulty — all 14 final-round reviewer scores, on a 5-point scale calibrated to a senior CPA/JD baseline:
| Rating | Reviews |
|---|---|
| Trivial | 0 |
| Easy | 0 |
| Moderate | 8 |
| Hard | 4 |
| Very Hard | 2 |
Representativeness — how often a practitioner encounters this scenario, across the same 14 reviews:
| Rating | Reviews |
|---|---|
| Rarely Encountered | 1 |
| Uncommon | 2 |
| Somewhat Typical | 6 |
| Typical | 5 |
| Core Activity | 0 |
Each task contributes exactly two scores, so these distributions describe reviewer judgments rather than tasks — 14 judgments across 7 tasks.
Who wrote and reviewed these tasks
The pilot cohort were US corporate tax specialists averaging roughly 18 years of practice — CPAs, Enrolled Agents, and tax attorneys, drawn from Big 4, national, and regional firm backgrounds, in Tax Partner, Director, and Senior Manager roles. Credentials in advanced taxation, law, and accounting.
Admission was gated: CV screening, a domain-knowledge assessment calibrated to professional-exam difficulty, and a three-module training program on model behavior, prompt construction, and peer-review standards. Experts who did not clear the assessment threshold were not assigned tasks.
These seven tasks are a sample of that cohort's output; the figures above describe the cohort, not the seven authors individually.
Quality assurance
Six stages. The first two and the last apply to every task; adjudication, revision, and second-round review are triggered only when review surfaces a problem.
1 · Automated quality gate. Every task. Before any human review, an LLM evaluator independently solves the case and compares its result to the submitted ground truth, distinguishing material errors — a wrong rate, a wrong statutory conclusion — from formatting and rounding differences. It separately audits whether the reasoning trace supports the stated answer, since reasoning that contradicts a correct answer is still a defect. Every submission is also screened for AI-generated text and plagiarism. All seven tasks passed; the result is recorded in AI Check.
2 · Dual independent peer review. Every task. Two domain experts review the task blind, without visibility into each other's assessment. Each rules on ground-truth correctness, evaluates whether the prompt is unambiguous and answerable, and scores difficulty and representativeness with written reasoning.
3 · Adjudication. 2 of 7 tasks. A third expert is brought in when reviewers disagree on the ground-truth verdict, or when their difficulty scores diverge sharply. The adjudicator issues the binding ruling. Flagged per task in Adjudication in Final Round. Because the triggering disagreement usually sits in a round that is not published, the flag cannot be reconstructed from the two reviews in this file.
4 · Revision. Where review required it. The original author addresses the feedback — clarifying ambiguous constraints, correcting statutory or arithmetic errors, resequencing or completing reasoning steps — and resubmits.
5 · Second-round review. 4 of 7 tasks. Independent experts re-evaluate the revised task. Renewed disagreement dismisses the task rather than forcing consensus. Recorded per task in Peer Review Rounds.
6 · Final approval. Every task. An additional correctness check, on the reasoning that these carry the most benchmark signal and the least tolerance for a wrong answer. A project lead approves the batch for release.
Field reference
21 columns in three groups. No column is empty and no row has a missing value.
Task content
| Column | Type | Description |
|---|---|---|
Task ID |
string | Stable task identifier. Values are non-contiguous — they are the original corpus identifiers. |
Question Type |
string | One of the six categories above |
Prompt |
string | The tax scenario as written by the expert, including the practitioner persona and constraints |
Reasoning Steps |
string | The expert's stepwise derivation, serialized as a list of {step_id, reasoning_step} objects |
Ground Truth |
string | The authoritative answer |
AI Check |
string | Result of automated AI-authorship and plagiarism screening. Pass for all seven tasks. |
Sources and Material |
string | IRC sections, regulations, rulings, and publications relied upon |
Review process
| Column | Type | Description |
|---|---|---|
Peer Review Rounds |
int32 | 1 or 2 — whether the task cleared review on the first pass or required revision and a second round |
Adjudication in Final Round |
bool | Whether a third expert was brought in to settle a disagreement |
Final peer reviews
Two blocks, Review 1 - and Review 2 -, holding the two reviews that closed the task out. Both are fully populated for every task.
| Field | Type | Description |
|---|---|---|
Ground Truth Examination |
string | Correct / Incorrect verdict. Correct throughout — see Limitations. |
Prompt Feedback |
string | Assessment of scenario clarity and answerability, often including the reviewer's own working |
Difficulty |
string | Reviewer's difficulty rating |
Difficulty Reasoning |
string | Written justification for the difficulty rating |
Representativeness |
string | Reviewer's frequency rating |
Representativeness Reasoning |
string | Written justification for the frequency rating |
The two blocks are independent reviewers rather than two rounds. On the two tasks where Adjudication in Final Round is true, one of the blocks is the adjudicator's binding ruling rather than a peer assessment — the blocks are not interchangeable on those rows.
Personal and sensitive information
The dataset contains no personal data. Scenarios are constructed for evaluation and describe hypothetical taxpayers, not real ones; cited authorities are public statutes, regulations, and rulings. Author and reviewer identities are not published.
Intended uses
Built for: evaluating frontier-model reasoning on statute-dependent corporate tax problems · inspecting how expert-authored evaluation data is constructed, reviewed, and adjudicated · studying how experienced practitioners calibrate difficulty and representativeness, including where they disagree · assessing whether this methodology fits your evaluation needs.
Not built for: statistically significant model benchmarking at this sample size · training a tax-advice system · tax advice, filing positions, or professional guidance of any kind.
Nothing here is tax advice. These scenarios are constructed for model evaluation. Do not rely on them for any real filing position.
Limitations
Stated plainly, because a dataset card that hides its own caveats is not worth trusting.
Seven tasks. Five of the six question types have exactly one task; only Statutory Interpretation has two. Treat the taxonomy as a description of coverage, not a balanced distribution, and do not draw statistical conclusions at this sample size.
Only the final round is published. Each task carries the two reviews that closed it out. First-round reviews, superseded assessments, and adjudicator reasoning from earlier rounds are held internally. The consequence is that all 14 published verdicts read
Correct: the dissent that drove revision on four of the seven tasks is not in this file.Peer Review RoundsandAdjudication in Final Roundrecord that friction occurred without reproducing it.Three reviewer fields from the source export are absent. The written justification for the ground-truth verdict is
N/Ain all 14 final-round reviews, so it was dropped. The step-level critique of the reasoning trace, and a yes/no flag summarizing it, survive in only 2 of the 14 — both onReview 1, for tasks #14 and #28 — and were dropped rather than shipped as columns that would be null for six of seven rows. The reasoning trace itself is present inReasoning Steps; what is missing is the reviewer's audit of it.AI Checkcarries no variance. It isPassfor all seven tasks, so it documents that screening happened rather than differentiating between rows.There is no single task-level difficulty label. Author self-assessments are excluded, so difficulty and representativeness exist only as individual reviewer judgments. Deriving a task-level rating — by majority, mean, or adjudicated verdict — is left to the user, deliberately, because the aggregation choice is itself a modeling decision.
Reviewer ratings are expert judgment, not ground truth. They are calibrated to a senior practitioner baseline, and the two reviewers on a task frequently diverged — on difficulty for 4 of 7 tasks and on representativeness for all 7. That disagreement is preserved rather than averaged away.
Reviewer commentary is substantively unedited. Written justifications appear as submitted, including abbreviations, shorthand computations, and informal phrasing; no wording was rewritten or tidied, because the raw record is more useful than a polished one. The only processing applied was trimming leading and trailing whitespace and normalizing empty and
N/Acells.Reasoning Stepsis a serialized string, not a native nested column. Parse it before use; it will not render as expandable structure in the dataset viewer.
License
Released under the Creative Commons Attribution 4.0 International license (CC BY 4.0).
You are free to share and adapt this dataset for any purpose, including commercially, provided you give appropriate credit to Human Edge, link to the license, and indicate whether changes were made.
The license covers Human Edge's contribution — the scenarios, ground-truth answers, reasoning traces, and review ratings. It does not grant rights in the third-party statutes, regulations, and rulings cited within the tasks; those remain governed by their own terms. It does not extend to the remainder of the corpus.
Citation
If you use this dataset, please cite it:
BibTeX:
@misc{humanedgeai2026corptaxes,
title = {Corp\_Taxes: Expert-Authored US Corporate Tax Reasoning (Pilot Sample)},
author = {{Human Edge}},
year = {2026},
publisher = {Hugging Face},
url = {https://huggingface.co/datasets/HumanEdgeAI/Corp_Taxes}
}
APA:
Human Edge. (2026). Corp_Taxes: Expert-Authored US Corporate Tax Reasoning (Pilot Sample) [Data set]. Hugging Face. https://huggingface.co/datasets/HumanEdgeAI/Corp_Taxes
About Human Edge
Human Edge builds expert human data for AI development — SME-based evaluation, benchmarking, and reinforcement learning from expert feedback in domains where correctness requires professional judgment: finance, legal, healthcare, and tax.
This dataset is a sample of the pilot phase of a larger program. The production methodology scales the cohort, the review pipeline, and the volume well past what is shown here.
To discuss an evaluation or benchmarking engagement: humanedgetech.ai
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