tag:blogger.com,1999:blog-1280984116620265503.post191667656674593234..comments2024-02-03T01:12:25.955-05:00Comments on THE TAX PROFESSIONAL: A TWITTER CONVERSATION CONTINUESRobert D Flachhttp://www.blogger.com/profile/06034127763662917220noreply@blogger.comBlogger3125tag:blogger.com,1999:blog-1280984116620265503.post-18986357114024561372012-12-28T14:11:40.880-05:002012-12-28T14:11:40.880-05:00"There are 300,000 PTIN-holders who need to p..."There are 300,000 PTIN-holders who need to pass the test in 2013. I do not know how many participants are permitted in each test. If it is 30 it means that the test needs to be offered 10,000 times in 2013. Even if 60 can take the test at a time that is 5,000 separate tests. That would be 100 tests in each state or 8 in each state each month."<br /><br />I counted around 275 separate testing facilities (http://www.irs.gov/Tax-Professionals/Registered-Tax-Return-Preparer-Test-and-Special-Enrollment-Examination-Test-Center-Locations). There is one in every state (including PR and DC).<br /><br />You can schedule the exam up to 6 months ahead of time (page 5 of http://www.irs.gov/pub/irs-utl/rtrpcandidateinfobulletin.pdf). So it can be reserved now and not be taken until the end of June. That leaves candidates another 6 months to retake the test if the flunk it the first time.<br /><br />300,000 divided by 275 = 1,091 candidates per test site.<br /><br />There are at least 150 business days between 4/16 and 12/31 (note that the Prometric center closest to me also allows Saturday exams). So if every potential RTRP candidate were to take the test, each site would have to administer 7 RTRP exams each day on average.<br /><br />Doable??? You betcha!Dave Fazio EAhttps://www.blogger.com/profile/14090479501410544820noreply@blogger.comtag:blogger.com,1999:blog-1280984116620265503.post-43204109981232867002012-12-28T13:14:33.318-05:002012-12-28T13:14:33.318-05:00Dave-
I support the registration of professional ...Dave-<br /><br />I support the registration of professional tax return preparers, and have from the beginning. I also strongly support the annual CPE requirements, and feel they should apply to all individuals who want to prepare 1040s for compensation, regardless of the initials that appear after their name. <br /><br />I have no problem with paying $63.00 per year as an annual licensure fee (although I would prefer to pay less – and I hate having to pay the State of New York $100 in extortion in order to be able to prepare 20 or so NY state income tax returns). <br /><br />I have been taking on average more than the required 15 hours of CPE in federal taxation (probably at least 20), as well as additional hours of state tax CPE, each year for over 25 years now. I have no problem with the cost of CPE – and agree that it is a cost of business. I have continually said that any serious tax return preparer who was not already taking at least 15 hours of CPE each year should have been. <br /><br />I do not support the initial competency test, although I can see that there may be a need to weed out complete incompetents. I do not believe that the IRS cares one hoot about having tax preparers prove competence, since more than half of the current PTIN-holders are exempt from the test (only EAs should be exempt from anything). <br /><br />I also feel that I, who have been preparing 1040s consistently without incident for over 40 years, should NOT be forced to take a test to prove that I know what I have been doing all these years, and that there should be some kind of grandfathering for those like me. I do not offhand remember the cost of the exam, but whatever it is I believe it is a waste of my money. I do, however, feel that I should be required to prove that I remain current by maintaining annual CPE in federal taxation, as should all paid tax preparers. <br /> <br />I do not believe that 12 months is enough time for the balance of the untested previously unenrolled PTIN-holders to all sit for and pass the test. Let us look at the logistics.<br /><br />There are 300,000 PTIN-holders who need to pass the test in 2013. I do not know how many participants are permitted in each test. If it is 30 it means that the test needs to be offered 10,000 times in 2013. Even if 60 can take the test at a time that is 5,000 separate tests. That would be 100 tests in each state or 8 in each state each month. I do not know any serious experienced tax pros who can afford to take the time to sit for the test during the tax season – so that knocks about 3 months off the testing time. <br /><br />So the bottom line is that 300,000 PTIN-holders have 9 months in order to pass the test – which I believe is virtually impossible.<br /><br />While I can understand your thinking concerning the IRS not wanting to show weakness and extend the deadline after taking such a hard line - as I have said before, it would be a disaster for the IRS, the taxpayer public, and the tax preparation industry for the Service to force potentially 200,000 tax professionals out of business. The Obama Administration wants to reduce unemployment, and not increase it!<br /><br />TWTP<br />Robert D Flachhttps://www.blogger.com/profile/06034127763662917220noreply@blogger.comtag:blogger.com,1999:blog-1280984116620265503.post-55844530716275239092012-12-28T12:16:07.422-05:002012-12-28T12:16:07.422-05:00I've made no bones about being pro-testing. I...I've made no bones about being pro-testing. I have, however, considered tweeting @Pontifex help get the special dispensation you truly deserve Robert. <br /><br />As of now, tax preparers that aren't EAs, attorneys (like that makes any sense), CPAs or already-registered RTRPs have one year and 3 days to pass the initial test of competency. That's a generous amount of time IMHO.<br /><br />The testing fee is not a burden on preparers (though I do feel bad for preparers who may have to travel 100s of miles from remote areas in order to take the test). The cost of the CE requirement is just another cost of doing business, as is refreshing your PTIN every year. <br /><br />So you have $116 to initially become a RTRP. You have $125 for your annual PTIN fee. 15 hours of CPE can run as little as nothing but let's say it is $500/year. If a preparer has 200 clients you are looking at a cost of $4/client return. I don't think raising fees $4 across the board is going to put any small preparer out of business.<br /><br />As of right now, the IRS is working preparer registration/regulation from a position of strength. They have set a deadline for testing that is more than fair. The fee for taking the test is also fair. The CPE requirement gives limited assurance to the IRS, the industry and the clients that the preparer is up-to-date on the changes. Preparers have been told they will not be allowed to prepare returns without credentials if they don't pass the test. Should the IRS back off the deadline they will prove to be a weak agency doing a poor job of regulating the industry. From where I stand, if the preparers can't get their sh*t together in a year and pass the test, they should be put out of business. <br /><br />I don't like having to show up at the RMV every few years to renew my license, but I do find being able to drive a car very convenient so I haul my butt there every few years, pay the idiot behind the RMV counter and get my picture taken. It's a 2 hour ordeal that I can do without but it beats having to take a cab everywhere.Dave Fazio EAhttps://www.blogger.com/profile/14090479501410544820noreply@blogger.com