Wednesday, January 19, 2011


He who thinks CPAs and attorneys walk on water has commented on my recent annual “Don’t Assume” post -

But Flach must make the false comparison because anyone in his right mind would choose an experienced tax preparer with the letters CPA after his name over a purportedly experienced tax preparer with no letters after his name.

It’s not the letters that are important, but rather what they represent. The lack of letters represents something, too:

1. The unenrolled preparer is incapable of obtaining a CPA or IRS Enrolled Agent designation (or has tried to do so and failed);

2. The unenrolled preparer is lazy and doesn’t want to do the work required to obtain a designation;

3. The unenrolled preparer is insufficiently committed to his purported profession; or

4. The unenrolled preparer believes that the entire licensing regime is bogus and, by God, he isn’t about to subject himself to oversight by no damn gub’ment agency.

Pick any one. I wouldn’t want someone like that preparing my tax return

To this nonsense I reply -

More than 300 taxpayers in their right mind choose me, an experienced tax preparer with “no letters after his name”, over an experienced tax preparer with the letters CPA after his/her name each year, and have been doing so for decades. And many thousands of taxpayers in their right mind choose other experienced and currently uninitialled tax preparers over initialed ones each year.

I have never pursued “initials” because I have no desire to either audit financial statements or represent taxpayers before the IRS.

(1) I am certainly capable of obtaining either a CPA or EA designation – I have just chosen not to do so because there was no need to do so. I have never attempted to do either and failed.

(2) I am not lazy – I just see no need to do unnecessary work to obtain unnecessary initials I neither want or need.

(3) I have certainly proven that I am more than sufficiently committed to the tax preparation profession.

(4) I have vocally supported, for the most part, the current IRS tax preparer regulation regime. I have submitted my application and my PTIN has been “fabrezed”. I do not fear proper government oversight. I actually welcome the ability to have my training and experience, and competence and currency, recognized by being given the initials RTRP (Registered Tax Return Preparer).

Once the regulation regime is fully phased-in, and previously unenrolled preparers like myself are given the RTRP designation, the taxpayer public will know that only those individuals with the initials RTRP or EA after their name have proven competence and remain current in federal income tax preparation.


chris said...

Thoughtful post, though your use of the word 'fabrezed' is worth the price of admission.

Robert D Flach said...


I cannot tell a lie. Nor can I take credit for the term "fabrezing".

That is the expression that IRS tax preparer regulation "czar" David Williams used in his presentations on the new regime last summer. He said that tax professionals who already had PTINS would need to "refresh" or "Fabreze" their PTIN as part of the program.