CPA Seeks Delay of Exam Requirement Under Proposed Regs on PTIN User Fees

I am a CPA and I support the goals to increase compliance and raise the ethical conduct of paid preparers embodied in your proposal to regulate paid income tax preparers. However, the costs and burdens of this proposal go too far, too fast -- we need to see a reasoned, rational approach that creates benefits that outweigh the burdens on the CPA preparer community and ultimately the tax-paying public.

CPA firms stand behind the work done by the CPAs and employees of their firms. Requiring PTINs on tax returns should give the IRS enough information to track and weed out incompetent preparers, WITHOUT the need to require PTINs for non-signing preparers at CPA firms. CPAs are already regulated by state boards of accountancy and Treasury Department Circular 230, so I believe strongly that the PTIN requirement should not be extended to non-signing preparers at CPA firms. CPAs already have a lot of continuing education and costs to deal with. This proposal is a waste of time and money!

I also feel strongly that the exam component should be delayed until evidence is gathered that proves the need for such an exam. The goal is to raise competency and ethical conduct; therefore; the PTIN tracking proposal should be given time to do just that, before layering on potentially unnecessary and redundant regulatory burdens on CPA firms in particular, and on all preparers and the public. In addition, I have concerns about certain aspects of the proposed Circular 230 rules that were recently released.

I request that the IRS: (1) exempt CPA firms from the non-signing preparer requirements of the proposed regulations, and (2) delay the implementation of the exam requirement until the PTIN process is fully implemented and results are known.

Thank you for your consideration of my thoughts on these important issues.