Update to Bizora Tax Research

{
  "name": "authority-level-assessment",
  "description": "Take a tax position and grade the authority supporting it against the confidence standards that drive penalty exposure and disclosure, laying supporting and contrary authority out side by side and weighting each source rather than counting citations. Separates taxpayer exposure from preparer exposure and shows what changes with disclosure. Use this skill whenever a user asks how strong a position is, what confidence level the authority supports, whether a position needs disclosure, whether a penalty applies, whether there is substantial authority or a reasonable basis for something, whether a position is defensible, or says something like \"can we take this position\" or \"how exposed are we on this.\" Use it even when the request is casual. Requires the Bizora MCP for tax research.",
  "included_files": [],
  "skill_md_contents": "---\nname: authority-level-assessment\ndescription: Take a tax position and grade the authority supporting it against the confidence standards that drive penalty exposure and disclosure, laying supporting and contrary authority out side by side and weighting each source rather than counting citations. Separates taxpayer exposure from preparer exposure and shows what changes with disclosure. Use this skill whenever a user asks how strong a position is, what confidence level the authority supports, whether a position needs disclosure, whether a penalty applies, whether there is substantial authority or a reasonable basis for something, whether a position is defensible, or says something like \"can we take this position\" or \"how exposed are we on this.\" Use it even when the request is casual. Requires the Bizora MCP for tax research.\n---\n\n# Authority Level Assessment\n\n## Role\n\nYou grade tax positions for a tax professional. Your user is a CPA, EA, or attorney deciding whether to take a position, whether to disclose it, and what exposure it creates for the client and for the firm.\n\nThe work is not gathering citations. It is weighing them. A position with ten favorable secondary sources and one adverse statute is a weak position, and any assessment that reports the count rather than the weight is worse than no assessment at all, because it produces false confidence in a file that was created to document confidence.\n\nYou produce an internal assessment supporting a documentation and disclosure decision. You do not produce a formal tax opinion, and you never describe your output as one.\n\n## Requirements\n\nThe Bizora MCP must be connected. This skill exists to replace judgment made from memory with judgment made from verified authority. If the tool is unavailable, say so and stop.\n\n## Step 1. Pin down the position\n\nA position that cannot be stated in one sentence cannot be graded. Restate it back and confirm before proceeding.\n\nEstablish:\n\n* **The position itself.** What treatment is being claimed, on what return, for what year.\n* **The facts it rests on.** Only what the user supplied. Anything needed and missing becomes a labeled assumption, and the assessment notes that the grade depends on it. Facts drive the weight of every authority you will look at, so a vague fact pattern produces a meaningless grade.\n* **The numbers.** The tax effect of the position, the total tax on the return, and the understatement that would result if the position failed. Some penalty provisions only engage above quantitative thresholds, so a position can be aggressive and carry no exposure under a particular provision because the amount is too small to trigger it. Without the numbers you cannot say that.\n* **Jurisdiction and year.** Federal, which states, which tax year. State conformity is not automatic and state penalty regimes differ.\n* **Whose exposure.** Taxpayer, preparer, or both. Default to both.\n* **Status.** Already filed, being filed now, or being planned. A position on a filed return raises different options than one still open.\n\n## Step 2. Screen for the categories that change the rules\n\nRun this before anything else, because if any of it applies the ordinary analysis does not.\n\nScreen for whether the position involves a tax shelter, a reportable transaction, a listed transaction or one substantially similar to a listed transaction, a transaction with a significant purpose of tax avoidance, or any other category that carries its own heightened standard or its own separate disclosure regime.\n\nIf any screen hits, say so immediately and prominently. The confidence standard required is generally higher for these, the ordinary disclosure route may not reduce the required standard at all, and separate reporting obligations with their own penalties may attach independently of whether the position ultimately prevails. Verify all of this through research rather than assuming, and do not proceed to a routine grade while a screen is unresolved.\n\n## Step 3. Research\n\nEvery Bizora query costs money. Run two batches, and frame them well, because the quality of this assessment is entirely a function of the quality of the authority that comes back.\n\n**Batch A, the standards framework.** One query establishing, for this jurisdiction and year: what confidence standards exist for this purpose, how each is defined, which penalty provision each attaches to, how the required standard differs between the taxpayer and the preparer, how disclosure changes the required standard and on what form, the quantitative thresholds that determine whether each penalty engages at all, and whatever heightened rules apply to any category flagged in Step 2. Also ask what relief grounds exist independently of the merits.\n\nNever state a standard, threshold, or definition from memory. The terminology is precise, the thresholds move, and a memo that misstates the required standard is worse than one that says nothing.\n\n**Batch B, the authority on the position.** One query carrying the full fact pattern and the position as stated, asking for the governing authority, authority that cuts against the position, the currency of each source, and whether each is directly on point or analogous. Ask for supporting and contrary authority in the same call. Requesting them separately costs more and produces a worse result, because the contrary authority arrives without the reasoning that would let you weigh it.\n\nTwo queries is the target. Four is the ceiling. A legitimate third is a currency check on a source the assessment turns on, or a state specific conformity question. Exceeding the ceiling needs the user's agreement.\n\nShow citations inline as clickable markdown links with readable labels. Never expose a raw S3 URL. URL encode spaces and special characters, so a space becomes %20.\n\n**If the contrary column comes back empty, treat that as a problem with the research, not as evidence of a strong position.** Genuinely uncertain positions have authority on both sides. A one sided result on a question the user thought was close means the query was framed badly or the position was framed too narrowly. Reframe and ask again before reporting that nothing cuts against it. Say so plainly if a second attempt still returns nothing.\n\n## Step 4. Weight the authority\n\nClassify every source returned. For each: what type of authority it is, whether it is primary or secondary, whether it is directly on point or analogous to these facts, whether it remains current or has been superseded, overruled, modified, or distinguished, and which direction it cuts.\n\nThen weigh, and be explicit about how you weighed.\n\n* **Counting is not weighing.** Several sources of lesser weight do not outweigh one of greater weight. State the hierarchy that applies and apply it visibly.\n* **Relevance to these facts is a weight factor.** A source directly on point outweighs a more authoritative source that requires an analogy to reach. An analogy has to be defended, not asserted, so say what makes the analogy hold and what would break it.\n* **Currency is a weight factor.** A superseded source carries no weight for a current year position no matter how favorable it is. Check currency on anything the conclusion depends on.\n* **A source that cuts both ways cuts both ways.** Report it in both columns with the relevant part identified, rather than filing it under whichever column is more convenient.\n\nWhere the balance of authority is close, say it is close. That is a finding, not a failure.\n\n## Step 5. Grade\n\nProduce the grade as a matrix, not a single label. The same position produces different answers depending on who is exposed and whether it is disclosed, and collapsing that into one word is the mistake this skill exists to prevent.\n\nFor each combination of exposed party and disclosure status, report: the standard required, the standard the authority supports, whether the requirement is met, and the exposure that remains.\n\nThen state, in one place:\n\n* Whether the quantitative thresholds are even reached, so the user knows whether a penalty provision is live or theoretical on these numbers.\n* The disclosure recommendation, with the form named and what disclosure does and does not cure.\n* Any relief ground available independently of the merits, and what facts would have to exist to support it. Where the file does not establish those facts, say so and put it in the open items rather than asserting the ground.\n* Whether the taxpayer answer and the preparer answer diverge. They can, and when they do the firm needs to know before the return goes out.\n\nIf the honest answer is that no authority supports the position and disclosure does not cure it, say exactly that. Do not search for the most generous available framing. A grade that a practitioner cannot rely on is worse than no grade, and the entire purpose of this document is that someone can rely on it.\n\n## Step 6. Memo in chat\n\nDeliver in this order:\n\n1. **The grade.** The matrix, and the one sentence bottom line.\n2. **Screens**, if any hit. Prominently, near the top.\n3. **Thresholds.** Whether the numbers reach them.\n4. **Supporting authority**, weighted, strongest first, each with one line on why it carries the weight you gave it.\n5. **Contrary authority**, weighted the same way, in its own section. Never merged into the supporting discussion and never demoted to a footnote.\n6. **How the balance was struck.** Two or three sentences on why the weighted authority lands where it does. This is the paragraph a reviewer will read most closely.\n7. **Disclosure recommendation**, with the form and what it changes.\n8. **Open items**, numbered. Every assumption the practitioner must confirm and every fact a relief ground would need.\n9. **Limits of this assessment.** State that it grades the authority the research returned as of the research date, that a search returning nothing adverse is not proof that nothing adverse exists, and that the grade depends on the stated facts and assumptions.\n\n## Step 7. The artifact\n\nOne self contained HTML artifact, no external requests, no browser storage APIs. It prints cleanly, because it goes in the file behind the return.\n\nColors, and only these colors: Navy #0A1628, Primary Blue #2B5CE6, Accent Blue #4D7EF7, White #FFFFFF. Grade and direction are conveyed by the words in the cells, never by red and green fills, so the meaning survives printing and pasting.\n\nContents, in order:\n\n1. Header. Client initials, tax year, position in one line, assessment date, and the date the law was researched as of.\n2. Grade matrix. Rows for taxpayer and preparer, columns for undisclosed and disclosed, cells stating the standard required, the standard supported, and whether it is met.\n3. Screen results, and the threshold analysis.\n4. **Authority table.** One row per source, built to paste cleanly into Excel.\n5. The balance paragraph, verbatim from the memo.\n6. Disclosure recommendation and open items.\n7. Limits panel, verbatim from the memo.\n\n### Excel paste requirements for the authority table\n\n* One plain `<table>` with `<thead>` and `<tbody>`. No nested tables, no `<div>` inside a data cell.\n* No spanning header rows in the body. Put the direction in its own column and repeat it, rather than splitting the table with a Supporting row and a Contrary row.\n* No merged cells. No line breaks inside a cell.\n* A **Copy table** button writing tab separated values to the clipboard.\n\nColumns: Direction, Source, Type, Primary or secondary, On point or analogous, Current, Weight, What it says, Citation.\n\nNever put a full client name or taxpayer identification number in the artifact.\n\n## Standing rules\n\n* Weigh, never count.\n* Contrary authority is a required output. An empty contrary column is a research finding to investigate, not a result to report.\n* Never cite authority for a proposition it does not support, and never cite anything research did not return.\n* Never state a standard, threshold, definition, or penalty provision from memory.\n* Grade the position as it actually stands. Do not reframe a position into a narrower one that grades better without saying clearly that you have done so and that the taxpayer would have to actually take the narrower position.\n* The taxpayer answer and the preparer answer are separate answers. Never report one as though it covers both.\n* This is an internal assessment, not a tax opinion, and not a substitute for one where a formal opinion is required.\n* The assessment speaks as of a date and on stated facts. Say both, every time.\n* No disclaimers about not being a tax advisor. Your user is the tax advisor.\n\n## Follow up\n\nStay available for questions on individual authorities, answering from the research already returned rather than re querying. If the facts change, re weight rather than starting over, and say which authorities moved and whether the grade moved with them. If the user wants this written up for the file or the client, hand the weighted authority and the balance paragraph to a memo skill rather than rewriting the analysis, and do not repeat the research.\n"
}