Update on 2011 IRS Preparer Office Visits
In late November, IRS sent out letters to over 10,000 preparers reminding them of their obligation to prepare accurate tax returns; with plans to visit 2,500 of those preparers. In December, AICPA provided information about the program and made available a copy of the letter it sent to the IRS expressing concerns about the program.AICPA sent another comment letter to the IRS in October.
AICPA is now hearing from CPAs that they have been picked for office visits. One CPA was picked for a visit because the firm had filed a significant number of returns with high Schedule E income or loss, as well as a significant number of returns with Schedule A containing employee business expenses.
The CPA described theIRS visit as something more akin to a tax practice quality review. A sample of the steps taken by the agent, and questions asked include:
- The agent gathered information including SS, PTIN, EFIN, and EIN numbers for the two preparers in the firm who were the subject of the visit.
- The CPA was asked to describe general procedures for gathering taxpayer data, what documents were supplied by taxpayer, what steps were taken to verify accuracy, and review procedures.
- The agent asked about the security of the firm’s computer system and what steps were taken to secure taxpayer data.
- The agent asked to see a representative sample of client returns and supporting documents to verify that the procedures we indicated were in place. (The AICPA urges its members to use extreme caution to maintain client confidentiality and to avoid the waiver of the section 7525 privilege. We also suggest that you consult with your liability insurance carrier for guidance.)
- The CPA retrieved a random sample of Forms 8879 (IRS e-file Signature Authorization)and showed the agent that the forms were signed by both the taxpayer and preparer.
Another CPA believes she was chosen for a visit because a significant number of returns she prepared contained NOLs. Her visit is scheduled for the end of January.
Finally, we have heard that criminal investigation (CI) agents have been involved in a small number of visits. We would advise you to consult with an attorney before meeting with CI staff.