He will be familiar with the Treasury regulations and IRS rulings on that statute. He will penetrate the many court decisions involved in the litigation of the tax statute. He will have read tax articles and books that deal with the tax statute. It is improbable that your accountant has the training or experience that would permit him to penetrate the complexity of the tax law on a particular tax issue. It is also not likely that the accountant can take the time out of a busy accounting practice, working with numbers and preparing financial statements, to master the vast array of difficult tax law that bears on a tax statute.
Tax law is drenched with ambiguity where there is mostly no answer that is right or wrong.
However, not all tax attorneys are equal just as, for example, professional golfers have difference levels of skill and ability. Tax attorneys have different levels of creativity, insight and skill. This creativity may arise in many ways. A creative tax attorney will use interpretative skill to find support of a taxpayer position. A creative tax attorney will be able to identify inconsistencies by the IRS in its published positions or private ruling letters.