This literature implicitly assumes that the market is inefficient, i.e. that the market relies on bottom line accounting numbers without regard to the procedures used to generate them. t It is, however, not necessary for the stock market's price formation process to exhibit functional fixation in order to establish smoothing incentives; it is sufficient for claimholders to exhibit bounded rationality. Alternatively, it is sufficient for management to believe that the market relies on accounting numbers. A questionnaire study by Mayer-Sommer (1979) found that 83 per cent of Fortune 500 controllers rejected the idea of market efficiency. Managers may, however, have incentives to misrepresent their beliefs, especially to standard setters. Using an approach which controls for this, O'Keefe and Soloman's (1985) investigation of managers' comment letters to FASB provides further evidence that many managers do not believe in market efficiency. In all cases, ceteris paribus, the higher the variability of the firm's earnings, the stronger the incentive for management to smooth income.