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1 (tax planning) [Scholes and Wolfson,1992] (tax cost saving hypothesis) (accounting choice) (economic consequences) (financial reporting costs) (1) (financial reporting cost hypothesis) (earnings management) [Schipper,1989] (discretionary behavior) 1

consequences) (financial reporting costs) (1) (financial reporting

2 (2) (3) 34.5% [,1994] (accounting discretion) 2

3 discretion) (4) [,1994] (tax rules) 1 (5) (real 3

4 [,1997] [Watts and Zimmerman,1986] (a) (b) (c) (d) (e) (aggressive tax planning) 4

5 (a) (b) (c) (d) (e) 5

6 (a) (b) (c) (conformity rule) 6

7 [Cloyd,1995] (conformity decision) [Cloyd, Pratt and Stock,1996] (a) book/tax difference ; Schedule M-1 of Form 1120 IRS challenge (red flag) [Internal Revenue Service, 1982] defending [Cloyd,1995;Cloyd, Pratt and Stock,1996] (b) [Wolfson,1993] 7

1120 IRS challenge (red flag) [Internal Revenue Service,

8 [Watts and Zimmerman,1986] (owner controlled firm) (manager controlled firm) [Watts and Zimmerman,1986] (6) (7) 8

9 ,1994] (8) [ (a) [,1994] [Watts and Zimmerman,1986] (b) (9) [Watts and Zimmerman,1986] 9

10 [,1994;Sweeney,1994] [,1996 ] [Sweeney,1994] 10

11 (10) (charity hypothesis) (11) 11

12 [ ] (1) Scholes, Wilson, and Wolfson[1992] (nontax cost) nontax economic consequences [1998] (2) Holthausen[1990] [1997] (3) (refund by carry-back on net operating losses) (net operating losses carry over) (4) Seholes, Wilson, and Wolfson[1992] transaction timing Klassen[1997] (5) GNP (6) 12

carry-back on net operating losses) (net operating losses carry over)

13 [,1994] Wolfson[1993] Klassen [1997] (inside ownership concentration) (7) Penno and Simon[1986] (8) Dhaliwal, Salamon, and Smith [1982] owner-controlled: OC management-controlled: MC OC Watts and Zimmerman[1986;1990] (9) Price-Earnings Ratio : PER Wolfson[1993] (10) Wolfson[1993] [ p.321] (11) 13

owner-controlled: OC management-controlled: MC OC Watts and

14 [1995] [ ] Cloyd, C. Bryan, Jamie Pratt, and Toby Stock, "The Use of Financial Accounting Choice to Support Aggressive Tax Position: Public and Private Firms," Journal of Accounting Research, Vol.34, No.1 (Spring 1996), pp Cloyd, C. Bryan, "The Effects of Financial Accounting Conformity on Recommendations of Tax Preparers," Journal of the American Taxation Association (Fall 1995), pp Dhaliwal, D., G. L. Salamon, and E. D. Smith, "The Effect of Owner versus Management Control on the Choice of Accounting Methods," Journal of Accounting and Economics, Vol.4, No.1 (July 1982), pp Holthausen, R. W., "Accounting Method Choice: Opportunistic Behavior, Efficient Contracting and Information Perspective," Journal of Accounting and Economics, Vol.12, No.1-3 (January 1990), pp Internal Revenue Service, Internal Revenue Manual: Tax Audit Guidelines (IRS, 1982). Klassen, Kenneth J., The Impact of Inside Ownership Concentration on the Trade-off Between Financial and Tax Reporting, The Accounting Review, Vol.72, No.3 (July 1997), pp Penno, M., and D. T. Simon, " Accounting Choices: Public versus Private Firms," Journal of Business, Finance and Accounting, Vol.13 (Winter 1986), pp Ronen, J., and A. Aharoni, "The Choice among Accounting Alternatives and Management Compensation: Effects of Corporate Tax," The Accounting Review, Vol. 64, No.1 (January 1989), pp

50-70. Dhaliwal, D., G. L. Salamon, and E. D. Smith, "The Effect of Owner versus Management Control on the Choice of Accounting Methods," Journal of Accounting and Economics, Vol.4, No.

15 Schipper, Katharine, "Commentary on Earnings Management," Accounting Horizons, Vol.3, No.4 (December 1989), pp Scholes, Myron S., G. Peter Wilson, and Mark. A. Wolfson, " Firms' Responses to Anticipated Reduction in Tax Rates: The Tax Reform Act of 1986, " Journal of Accounting Research, Vol.30 (Supplement 1992), pp Scholes, Myron S., and Mark. A. Wolfson, Taxes and Business Strategy: A Planning Approach (Prentice-Hall, 1992). Sweeney, Amy Patricia, " Debt-Covenant Violation and Managers' Accounting Responses," Journal of Accounting and Economics, Vol.17, No.3 (January 1994), pp Wolfson, Myron S., " The Effects of Ownership and Control on Tax and Financial Reporting Policy, " Economic Note, Vol.22(1993), pp Watts, Ross L., and Jerold L. Zimmerman, Positive Accounting Theory (Prentice-Hall,1985). Watts, Ross L., and Jerold L. Zimmerman, "Positive Accounting Theory: A Ten Year Perspective," The Accounting Review, Vol. 65, No.1 (January 1990), pp

Sweeney, Amy Patricia, " Debt-Covenant Violation and Managers' Accounting Responses," Journal of Accounting and Economics, Vol.17, No.3 (January 1994), pp.281-308. Wolfson, Myron S.

Ver. 1.0 (discretion) (revenue management) (fictitious revenue recognition) (window dressing) (fraudulent accounting practice) SEC (General

2004.11.25 Ver. 1.0 (discretion) (revenue management) (fictitious revenue recognition) (window dressing) (fraudulent accounting practice) SEC (Generally Accepted Accounting Principles: GAAP) GAAP (realization