University of Tehran administers a test known as The University of Tehran English Proficiency Test (the UTEPT) to PhD candidates on a yearly basis. By definition, the test can be considered a high-stakes one. The validity of high stakes tests needs to be known (Roever, 2001). As Mesick (1988) maintains, if the validity of high stakes tests are not known, it might have some undesirable consequences for the society at large. To investigate the construct validity of the test, factor analysis was employed (Farahdy, 1983). The factor analysis of choice was exploratory factor analysis with varimx rotation strategy. In the reading section, the factor analysis produced eleven factors. Furthermore, the use of Principal Components Analysis (PCA) was complemented with Principal Axis Factoring (PAF). Overfactoring was an issue. This overfactoring can be attributed to the heterogeneous nature of items; different paradigms from which items were taken: iBT TOEFL, ILTES, and FCE.