Friday, June 27, 2014


The IRS’ newly announced voluntary “Annual Filing Season Program” is one of the stupidest things I have ever come across.

The program does not provide those who meet the testing and CPE requirements with an identifiable designation, with accompanying initials, like “Registered Tax Return Preparer” (and “RTRP”) that the recipient can use in advertising and promotion to identify his/her competence and currency in 1040 preparation.  Those who pass the test and take the CPE are merely placed on a list of IRS recommended preparers and given a plaque to hang in his/her office.

If the really IRS wants to help the taxpayer public identify competent tax preparers, who have been tested and remain current, it must provide a method of publicly identifying them – such as an actual credential.

In announcing the program, IRS Commissioner John Koskinen says, “Our program will give unenrolled tax return preparers a way to stay up-to-date on tax laws and changes, which we believe will improve service to taxpayers”.

The program does no such thing. Tax preparers already have, and take advantage of, multiple ways to stay up-to-date on tax laws and changes – tax-related CPE offered by NATP, NSTP, NSA, NAEA, private providers like Gear-Up, and the existing IRS Nationwide Tax Forums.

Serious tax preparers are already taking CPE in federal and state tax topics each and every year, many more than the 18 hours required by the new program.  .  Not because of any requirements – but out of necessity.  Others are “self-educating” via the internet.  This program will do little to “encourage education and filing season readiness”.

The online database, if it is indeed used by taxpayers seeking professionals, could be confusing if it is merely an alphabetic listing of all “record of completion” preparers mixed in with others of “recognized credentials {some with nothing to do with 1040 preparation – rdf} and higher levels of qualification and practice rights

To be done right the online database should contain all PTIN-holders only, since all PTIN-holders are "approved preparers", listed alphabetically by category of designation.  Instead of one big list there should be separate lists for Enrolled Agents, participants in the new voluntary program (with an identifiable designation and initials), unenrolled preparers, CPAs, attorneys, ERPAs, and enrolled actuaries.  The database should be prefaced with a statement that only Enrolled Agents and those holding the new designation have demonstrated competence and currency in 1040 preparation via a test and mandatory CPE in taxation.


1 comment:

Anonymous said...

The problem is that the IRS already has a voluntary credential that it's never bothered to promote, which is the EA.

Earth to IRS: If incompetent tax preparers are such a problem, stop promoting e-file at every turn (hello e-fraud) and start promoting the high quality voluntary program you've had in place for decades.

And yes, I'm an EA, so I would benefit. And I do agree with you in general: the issue of incorrect taxes is the overwhelming complexity of the tax code. Which the ACA promises to make worse. Regulating really won't solve any issues of fraud and incompetence.