AFSP - BOON OR BUST?

According to the “Return Preparer Office Federal Tax Return Preparer Statistics” page at www.irs.gov, as of September 1, 2017 there were a total of 722,662 “individuals with current Preparer Tax Identification Numbers (PTINs) for 2017).  When you subtract out the Enrolled Actuaries and Enrolled Retirement Plan Agents that leaves 721,549 actual tax return preparers.  This number consists of 296,082 “enrolled” PTIN-holders – Enrolled Agents, CPAs and attorneys – leaving 425,467 “unenrolled” or “un-credentialed” preparers.  Of these 54,485, or less than 13%, have elected to participate in the IRS’s Annual Filing Season Program (AFSP).

 

So, this relatively new program has not been very successful.  I have always believed that participation in the AFSP does not provide any real value to tax professionals, and it appears I am not alone in my belief.

 

There are so many things wrong with the AFSP.  For example -.

 

1. The program does not provide those who meet the requirements with an identifiable credential or designation, with accompanying initials that the recipient can use in advertising and promotion to identify their competence and currency in 1040 preparation. Those who pass the test and take the CPE are merely placed on a list of IRS “approved” preparers and given a plaque to hang in their office.

 

2. The program does not call for an initial competency test. Instead, participants must pass an annual “comprehension test” upon completion of the required six-hour “federal tax filing season refresher course.”

 

3. The public database, if it will actually be used by taxpayers seeking professionals (I doubt it will be), is large and confusing if it is merely an alphabetic listing of all “record of completion” preparers mixed in with others of “recognized credentials,” some which nothing to do with 1040 preparation (CPAs and attorneys), and “higher levels of qualification and practice rights.”  To be done correctly, the database should contain all PTIN-holders, since all individuals who have a valid PTIN are truly "approved preparers," listed alphabetically by category of designation. 

 

4. The new program should not be allowed to deny unenrolled tax preparers who chose not to participate the right to represent their clients before the service during an examination of a return that they have prepared and signed. All tax preparers with a valid PTIN must have the right to defend and explain, or assist their clients in defending and explaining, the tax returns they have personally prepared during the audit process.

 

So my question for fellow tax professionals this issue is –

 

Have you received any new clients from participating in the Annual Filing Season Program?

 

In the past when I asked this question at another venue all the answers I received were “no”.  Having a “record of completion” did not in any way help the practice of those who replied.

 

I also want to hear your thoughts and comments on the AFSP in general.  Email me at rdftaxpro@yahoo.com with THE TAX PROFESSIONAL QUESTION.

THE LAST WORD -

FYI - I have created a new Classified Advertising Page on my THE TAX PROFESSIONAL website.  Check it out.

 

TAFN