should tax preparers be certified competent?

four recommendations for congress.

by 卡塔尔世界杯常规比赛时间 research

sad news for all you enrolled agents, enrolled actuaries, attorneys, cpas and other trained, competent tax preparers: you wasted your time and money on education. it turns out incompetence isn’t illegal. there are no standards, no mandatory credentials. anyone can claim to be a tax preparer.

more: irs: let the sun shine in … and out | irs has big plans for its $80 billion | can’t irs tax pro accounts do more? | hello? irs? anybody home? | taxpayer assistance centers need upgrade | at the irs, short on staff means short on service
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best of all, when an incompetent preparer makes a mistake, it’s only taxpayers and the irs that suffer.

they don’t do a very good job

over half of all individual tax returns are prepared by preparers. but last year, as of september, non-credentialed preparers had prepared 58 percent of them.

generally speaking, the non-credentialed don’t do a very good job of it. one clear indicator: about 92 percent of dollars of audit adjustment made on 2020 returns claiming earned income tax credit occurred on returns prepared by non-credentialed preparers.

lack of minimum competence

the lack of minimum competence harms taxpayers in many ways:

  • taxpayers who don’t understand the differences in education and certification often end up paying for poor service.
  • taxpayers are financially and legally responsible for inaccurate returns.
  • inaccurate returns can result in either overpayment of taxes or penalties for underpayment.
  • low-income taxpayers, who can least afford penalties, are often targeted by the incompetent and unscrupulous.
  • there is more noncompliance in returns prepared by the non-credentialed.
  • the non-credentialed cannot represent taxpayers at irs audits.
  • the non-credentialed are not subject to standards of conduct and ethical rules.
  • inaccurate returns force the irs to waste time and funds on reacting to noncompliance.
  • returns prepared by incompetents often result in delays, audits, penalties and interest payments.

numerous studies have consistently found significant noncompliance on returns prepared by non-credentialed preparers.

once upon a time, the secretary of the treasury and the irs implemented a program regulating paid tax return preparers. but within a couple of years, the supreme court held that the irs has no such authority to impose preparer standards without statutory authorization. the non-credentialed lived happily ever after.

if the irs were authorized to do so by congressional legislation, it could bring all return preparers under the purview of circular 230, a body of regulations that provides standards of conduct and sanctions for violations for the profession. a minimum competency exam could include ethical standards.

undercover agents

though the national taxpayers advocate has been calling on congress to pass appropriate legislation, no such action has been taken. one study – conducted by the general accountability office, the treasury inspector general for tax administration, and the n.y. state department of taxation and finance – involved undercover agents seeking return preparation assistance from non-credentialed preparers. every return had significant inaccuracies.

an irs study in 2014 found that non-credentialed return preparers not affiliated with a national tax return preparation firm were responsible for “the highest frequency and percentage of eitc overclaims.” the overclaims averaged 33 to 40 percent.

ghost preparers

there may be some disadvantages to requiring standards of education or mandatory credentials.

one is that the requisite education would cost preparers time and money. some will do what they have to do and pass those costs on to clients. others may decline the credentials and go underground to prepare returns at a discount without signing them. those latter shysters are known as “ghost preparers.” when they are called upon to account for errors, they disappear into thin air.

there is also concern that an oversight program might drive preparers out of the profession simply because achieving competence involves investments in money and time.

the nta has sent to congress four recommendations that could eliminate this problem:

  1. conduct a robust outreach and education campaign on how to report suspected violations of circular 230, with the targeted recipients of these outreach and education efforts to include taxpayers, tax professionals and irs employees.
  2. strengthen taxpayer awareness immediately before and after the filing season to ensure that taxpayers know what to expect from preparers and where to report violations.
  3. prioritize the assessment and collection of preparer penalties, especially for failure to sign a return.
  4. amend title 31, section 330 of the u.s. code to authorize the establishment of minimum standards for federal tax return preparers.