Theory, practice, and research are all espoused to be core values within counselor education. The authors assert that research needs to become directly associated with theory and practice for it to be a concurrent core value. "Action research" is most simply defined as a form of research that is practitioner based. The authors propose infusing action research throughout master's-level curricula as a means of promoting research as a core value concurrent with theory and practice. A case illustration of an action research investigation in a Professional and Ethical Issues in Mental Health Counseling course is described.