December 9, 2010
ABA Tax Section Submits Comments on Circular 230The ABA Tax Section has submitted this comment letter on Circular 230:
Under the proposed amendments to Circular 230 the definition of “Practitioner” is expanded to include a new category of “Registered Tax Return Preparers,” defined by reference to § 7701(a)(3) and Reg. § 301.7701-15. This new category of practitioners is estimated to include 900,000 to 1.2 million individuals.
We concur in the proposed amendments to sections 10.2, 10.3, 10.4, 10.5 and 10.6 of Circular 230 providing jurisdiction to OPR to determine the competency and suitability of a Registered Tax Return Preparer. We believe regulation of tax return preparers by OPR to be an essential and long overdue component of an effective national tax compliance program. We also strongly support an increased enforcement program which will include increased oversight of paid tax preparers. A core of competent and ethical paid preparers must be a part of any strategy to strengthen the integrity of the tax system.
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How odd, that an organization of lawyers would support regulation of tax preparers (yes, some of us are lawyers) by an executive branch of the federal government. Does the ABA also support federal regulation of divorce lawyers?
The IRS is using its registration and regulation powers to intimidate practitioners into using electronic filing of income tax returns. The problem is not electronic filing, but the condition that come with it: Consent to random, unannounced inspections by IRS agents (some of them from the criminal investigation function) of practitioner offices and files.
Posted by: Bob | Dec 9, 2010 10:49:04 AM