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	<title>Comments on: CPA vs. Unenrolled Preparer: Tax Code Requires Good Books and Records</title>
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	<description>Pappas on Taxation</description>
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		<title>By: Unenrolled Tax Preparer Outfit Shut Down for Tax Fraud</title>
		<link>http://www.pappasontaxes.com/index.php/2009/07/04/new-tax-blog-alert-april15com/comment-page-1/#comment-7090</link>
		<dc:creator>Unenrolled Tax Preparer Outfit Shut Down for Tax Fraud</dc:creator>
		<pubDate>Thu, 16 Sep 2010 15:54:44 +0000</pubDate>
		<guid isPermaLink="false">http://blog.pappastax.com/?p=6769#comment-7090</guid>
		<description>[...] CPA vs. Unenrolled Preparer: Tax Code Requires Good Books and Records [...]</description>
		<content:encoded><![CDATA[<p>[...] CPA vs. Unenrolled Preparer: Tax Code Requires Good Books and Records [...]</p>
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		<title>By: IRS Notice Mailing Procedure Costs Taxpayers Millions</title>
		<link>http://www.pappasontaxes.com/index.php/2009/07/04/new-tax-blog-alert-april15com/comment-page-1/#comment-6395</link>
		<dc:creator>IRS Notice Mailing Procedure Costs Taxpayers Millions</dc:creator>
		<pubDate>Thu, 15 Jul 2010 22:35:03 +0000</pubDate>
		<guid isPermaLink="false">http://blog.pappastax.com/?p=6769#comment-6395</guid>
		<description>[...] If a you handled your business this inefficiently, the IRS would assess a hefty penalty against you for negligence. [...]</description>
		<content:encoded><![CDATA[<p>[...] If a you handled your business this inefficiently, the IRS would assess a hefty penalty against you for negligence. [...]</p>
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	<item>
		<title>By: Federal Tax Crimes</title>
		<link>http://www.pappasontaxes.com/index.php/2009/07/04/new-tax-blog-alert-april15com/comment-page-1/#comment-5778</link>
		<dc:creator>Federal Tax Crimes</dc:creator>
		<pubDate>Sun, 06 Jun 2010 23:29:15 +0000</pubDate>
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		<description>[...] this federal statute is to make sure you file an accurate return. The first step in doing this, is keeping good books and records. A second step would be to hire an experienced and qualified tax preparer to prepare your tax [...]</description>
		<content:encoded><![CDATA[<p>[...] this federal statute is to make sure you file an accurate return. The first step in doing this, is keeping good books and records. A second step would be to hire an experienced and qualified tax preparer to prepare your tax [...]</p>
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		<title>By: Taxes 101: Hobby or Legitimate Business? Good Records May Carry the Day</title>
		<link>http://www.pappasontaxes.com/index.php/2009/07/04/new-tax-blog-alert-april15com/comment-page-1/#comment-4215</link>
		<dc:creator>Taxes 101: Hobby or Legitimate Business? Good Records May Carry the Day</dc:creator>
		<pubDate>Fri, 05 Feb 2010 11:33:56 +0000</pubDate>
		<guid isPermaLink="false">http://blog.pappastax.com/?p=6769#comment-4215</guid>
		<description>[...] CPA v. Unenrolled Preparer: Tax Code Requires Good Books and Records  Bookmark &amp; Share: [...]</description>
		<content:encoded><![CDATA[<p>[...] CPA v. Unenrolled Preparer: Tax Code Requires Good Books and Records  Bookmark &amp; Share: [...]</p>
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	<item>
		<title>By: CPA, JD or _ _ _? Which is Better?</title>
		<link>http://www.pappasontaxes.com/index.php/2009/07/04/new-tax-blog-alert-april15com/comment-page-1/#comment-2075</link>
		<dc:creator>CPA, JD or _ _ _? Which is Better?</dc:creator>
		<pubDate>Sat, 01 Aug 2009 04:35:35 +0000</pubDate>
		<guid isPermaLink="false">http://blog.pappastax.com/?p=6769#comment-2075</guid>
		<description>[...] CPA vs. Unenrolled Preparer: Tax Code Requires Good Books and Records [...]</description>
		<content:encoded><![CDATA[<p>[...] CPA vs. Unenrolled Preparer: Tax Code Requires Good Books and Records [...]</p>
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	<item>
		<title>By: The Poli-tax of Personal Destruction?</title>
		<link>http://www.pappasontaxes.com/index.php/2009/07/04/new-tax-blog-alert-april15com/comment-page-1/#comment-1864</link>
		<dc:creator>The Poli-tax of Personal Destruction?</dc:creator>
		<pubDate>Sun, 12 Jul 2009 16:05:04 +0000</pubDate>
		<guid isPermaLink="false">http://blog.pappastax.com/?p=6769#comment-1864</guid>
		<description>[...]  [...]</description>
		<content:encoded><![CDATA[<p>[...]  [...]</p>
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		<title>By: Peter</title>
		<link>http://www.pappasontaxes.com/index.php/2009/07/04/new-tax-blog-alert-april15com/comment-page-1/#comment-1807</link>
		<dc:creator>Peter</dc:creator>
		<pubDate>Mon, 06 Jul 2009 04:28:04 +0000</pubDate>
		<guid isPermaLink="false">http://blog.pappastax.com/?p=6769#comment-1807</guid>
		<description>Oh, okay.

I&#039;m always looking for ways to improve my business.</description>
		<content:encoded><![CDATA[<p>Oh, okay.</p>
<p>I&#8217;m always looking for ways to improve my business.</p>
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		<title>By: The Tax Guy Agrees with Robert Flach: The Pompous Ass (that&#8217;s me, folks) Responds</title>
		<link>http://www.pappasontaxes.com/index.php/2009/07/04/new-tax-blog-alert-april15com/comment-page-1/#comment-1804</link>
		<dc:creator>The Tax Guy Agrees with Robert Flach: The Pompous Ass (that&#8217;s me, folks) Responds</dc:creator>
		<pubDate>Mon, 06 Jul 2009 04:22:05 +0000</pubDate>
		<guid isPermaLink="false">http://blog.pappastax.com/?p=6769#comment-1804</guid>
		<description>[...] RSS        &#8592; CPA vs. Unenrolled Preparer: Tax Code Requires Good Books and Records [...]</description>
		<content:encoded><![CDATA[<p>[...] RSS        &larr; CPA vs. Unenrolled Preparer: Tax Code Requires Good Books and Records [...]</p>
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		<title>By: Bruce</title>
		<link>http://www.pappasontaxes.com/index.php/2009/07/04/new-tax-blog-alert-april15com/comment-page-1/#comment-1803</link>
		<dc:creator>Bruce</dc:creator>
		<pubDate>Mon, 06 Jul 2009 04:10:53 +0000</pubDate>
		<guid isPermaLink="false">http://blog.pappastax.com/?p=6769#comment-1803</guid>
		<description>I wasn&#039;t aware my business needed help.

For some it might be, for me no. 

Again, I want the client because they know I am a tax pro not because they blindly believe I am.</description>
		<content:encoded><![CDATA[<p>I wasn&#8217;t aware my business needed help.</p>
<p>For some it might be, for me no. </p>
<p>Again, I want the client because they know I am a tax pro not because they blindly believe I am.</p>
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		<title>By: Peter</title>
		<link>http://www.pappasontaxes.com/index.php/2009/07/04/new-tax-blog-alert-april15com/comment-page-1/#comment-1801</link>
		<dc:creator>Peter</dc:creator>
		<pubDate>Mon, 06 Jul 2009 03:54:55 +0000</pubDate>
		<guid isPermaLink="false">http://blog.pappastax.com/?p=6769#comment-1801</guid>
		<description>Don&#039;t you think it might help your business if you were a CPA or IRS Enrolled Agent?

Isn&#039;t THAT a good enough reason?</description>
		<content:encoded><![CDATA[<p>Don&#8217;t you think it might help your business if you were a CPA or IRS Enrolled Agent?</p>
<p>Isn&#8217;t THAT a good enough reason?</p>
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		<title>By: Bruce</title>
		<link>http://www.pappasontaxes.com/index.php/2009/07/04/new-tax-blog-alert-april15com/comment-page-1/#comment-1800</link>
		<dc:creator>Bruce</dc:creator>
		<pubDate>Mon, 06 Jul 2009 03:49:06 +0000</pubDate>
		<guid isPermaLink="false">http://blog.pappastax.com/?p=6769#comment-1800</guid>
		<description>Just because something is assumed, does not make it so. Given all that has gone on the past few weeks, as a reader, I think now at this point I would begin to question the term CPA and try to become a bit more aware.

The CPA in my post, is a clear example of why there needs to be a better reign on “who is a tax preparer”, and that is where regulation will come in. At the same time if all of us (including CPAs)  are grandfathered in, then nothing will be any different for many years.

It isn’t just un-enrolled preparers that need regulated. Everyone who preparers returns for profit needs to be tested and regulated. EVERYONE!

An Attorney who has his/her specialty it tax law, this makes since for him/her to also become a CPA. As you stated, “CPAs have demonstrated the knowledge and ability to handle numbers and maintain proper books and records.”, A key to preparing an accurate return. (Having properly maintained books.)

How can you not agree that the general public associates tax pro with CPA? Even someone from the AICPA  acknowledges this believe by the general public. To not agree yourself would be delusional on your part, and I don’t believe that you are delusional. 

Do I need to copy and paste again the quote from the AICPA the quote that stated plainly that tax prep is an area for which the public already ‘believes’ CPAs to &#039;own&#039;.

It has been suggested that CPAs are aware of this belief. 

Why do we need regulation? 

Is this not reason enough? I mean if for no other reason, wouldn’t it be enough to separate the CPAs who have no business preparing returns from those who do? Or as a CPA, should it just be overlooked that there is one who can’t add or subtract (five places on one return), and has no clue about tax preparation, as one bad egg?

My personal decisions are just that, personal. However I will answer your question. I was a CPA has I keep pointing out, When client/taxpayers come to me for assistance I don’t want them doing so blindly just because I have a Certification for being a licensed bookkeeper. I want clients to come to me because I am known for my abilities as a “Tax Preparer”. That is why no CPA.
As for Not becoming an EA, well, Why? I mean a taxpayer regardless of all things is ultimately responsible for their own return. Right?     So in a situation before the IRS shouldn’t the taxpayer stand there before them? I believe they should. According to Circular 230, am I not allowed to be there? On the contrary, I am. (I can quote this area of the 230 if you’d like.)

I never figured you for a propaganda sponge. A lot is being said about un-enrolled prepares and how we need to regulate them. The blinding fact is all preparers need to be regulated. 

Why are un-enrolled prepares the talk and focus point of regulation? 

I cannot say for sure, but it surely couldn’t be because of the blind belief of the public that CPAs and others with professional designations calling themselves Tax pros are doing anything wrong. I mean aren’t they held accountable by private groups. 

Funny, I don’t see the AICPA arresting someone. Then again the IRS will. A designation won’t help either, A CPA will be penalized and possibly imprisoned just as any un-enrolled preparer.

I put this to you again, is not anyone/everyone who is a tax preparer (CPA or un-enrolled preparer) governed by Circular 230? 

Understandably there are limits placed on an un-enrolled preparer, but they are just as accountable to the IRS as a CPA or some other designation.</description>
		<content:encoded><![CDATA[<p>Just because something is assumed, does not make it so. Given all that has gone on the past few weeks, as a reader, I think now at this point I would begin to question the term CPA and try to become a bit more aware.</p>
<p>The CPA in my post, is a clear example of why there needs to be a better reign on “who is a tax preparer”, and that is where regulation will come in. At the same time if all of us (including CPAs)  are grandfathered in, then nothing will be any different for many years.</p>
<p>It isn’t just un-enrolled preparers that need regulated. Everyone who preparers returns for profit needs to be tested and regulated. EVERYONE!</p>
<p>An Attorney who has his/her specialty it tax law, this makes since for him/her to also become a CPA. As you stated, “CPAs have demonstrated the knowledge and ability to handle numbers and maintain proper books and records.”, A key to preparing an accurate return. (Having properly maintained books.)</p>
<p>How can you not agree that the general public associates tax pro with CPA? Even someone from the AICPA  acknowledges this believe by the general public. To not agree yourself would be delusional on your part, and I don’t believe that you are delusional. </p>
<p>Do I need to copy and paste again the quote from the AICPA the quote that stated plainly that tax prep is an area for which the public already ‘believes’ CPAs to &#8216;own&#8217;.</p>
<p>It has been suggested that CPAs are aware of this belief. </p>
<p>Why do we need regulation? </p>
<p>Is this not reason enough? I mean if for no other reason, wouldn’t it be enough to separate the CPAs who have no business preparing returns from those who do? Or as a CPA, should it just be overlooked that there is one who can’t add or subtract (five places on one return), and has no clue about tax preparation, as one bad egg?</p>
<p>My personal decisions are just that, personal. However I will answer your question. I was a CPA has I keep pointing out, When client/taxpayers come to me for assistance I don’t want them doing so blindly just because I have a Certification for being a licensed bookkeeper. I want clients to come to me because I am known for my abilities as a “Tax Preparer”. That is why no CPA.<br />
As for Not becoming an EA, well, Why? I mean a taxpayer regardless of all things is ultimately responsible for their own return. Right?     So in a situation before the IRS shouldn’t the taxpayer stand there before them? I believe they should. According to Circular 230, am I not allowed to be there? On the contrary, I am. (I can quote this area of the 230 if you’d like.)</p>
<p>I never figured you for a propaganda sponge. A lot is being said about un-enrolled prepares and how we need to regulate them. The blinding fact is all preparers need to be regulated. </p>
<p>Why are un-enrolled prepares the talk and focus point of regulation? </p>
<p>I cannot say for sure, but it surely couldn’t be because of the blind belief of the public that CPAs and others with professional designations calling themselves Tax pros are doing anything wrong. I mean aren’t they held accountable by private groups. </p>
<p>Funny, I don’t see the AICPA arresting someone. Then again the IRS will. A designation won’t help either, A CPA will be penalized and possibly imprisoned just as any un-enrolled preparer.</p>
<p>I put this to you again, is not anyone/everyone who is a tax preparer (CPA or un-enrolled preparer) governed by Circular 230? </p>
<p>Understandably there are limits placed on an un-enrolled preparer, but they are just as accountable to the IRS as a CPA or some other designation.</p>
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		<title>By: Peter</title>
		<link>http://www.pappasontaxes.com/index.php/2009/07/04/new-tax-blog-alert-april15com/comment-page-1/#comment-1799</link>
		<dc:creator>Peter</dc:creator>
		<pubDate>Mon, 06 Jul 2009 00:43:42 +0000</pubDate>
		<guid isPermaLink="false">http://blog.pappastax.com/?p=6769#comment-1799</guid>
		<description>Bruce, 

If you guys are right in saying that CPA&#039;s are assumed to be competent in tax preparation, then how could being a CPA NOT do anything for you?

I am confused.

Either CPAs have an unfair advantage over unenrolled preparers or they don&#039;t.

You can&#039;t have it both ways.

And are you also saying that being an enrolled agent would do nothing for you?

Robert says he would trust an enrolled agent to prepare a return before he would trust unenrolled preparers or CPAs.

How, then, could this designation NOT do anything for you?

By the way, if unenrolled preparers are so good, as Robert and now apparently you suggest, how come we need to regulate them at all?</description>
		<content:encoded><![CDATA[<p>Bruce, </p>
<p>If you guys are right in saying that CPA&#8217;s are assumed to be competent in tax preparation, then how could being a CPA NOT do anything for you?</p>
<p>I am confused.</p>
<p>Either CPAs have an unfair advantage over unenrolled preparers or they don&#8217;t.</p>
<p>You can&#8217;t have it both ways.</p>
<p>And are you also saying that being an enrolled agent would do nothing for you?</p>
<p>Robert says he would trust an enrolled agent to prepare a return before he would trust unenrolled preparers or CPAs.</p>
<p>How, then, could this designation NOT do anything for you?</p>
<p>By the way, if unenrolled preparers are so good, as Robert and now apparently you suggest, how come we need to regulate them at all?</p>
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		<title>By: Bruce</title>
		<link>http://www.pappasontaxes.com/index.php/2009/07/04/new-tax-blog-alert-april15com/comment-page-1/#comment-1798</link>
		<dc:creator>Bruce</dc:creator>
		<pubDate>Sun, 05 Jul 2009 22:36:53 +0000</pubDate>
		<guid isPermaLink="false">http://blog.pappastax.com/?p=6769#comment-1798</guid>
		<description>You say
 &quot;The good unenrolled preparers should do everything possible to either become CPAs or become IRS Enrolled Agents.&quot;

I ask:
Why? For what purpose?
Have you forgotten I support the need for tax preparer regulation even Tax Preparer Licensing?

I’ve had a license. It did nothing for me.

When preparer regulation is enacted, I’ll be first in line to do whatever is necessary. At that point I’ll be out front demanding that those falsely accredited the title be dealt with accordingly .</description>
		<content:encoded><![CDATA[<p>You say<br />
 &#8220;The good unenrolled preparers should do everything possible to either become CPAs or become IRS Enrolled Agents.&#8221;</p>
<p>I ask:<br />
Why? For what purpose?<br />
Have you forgotten I support the need for tax preparer regulation even Tax Preparer Licensing?</p>
<p>I’ve had a license. It did nothing for me.</p>
<p>When preparer regulation is enacted, I’ll be first in line to do whatever is necessary. At that point I’ll be out front demanding that those falsely accredited the title be dealt with accordingly .</p>
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		<title>By: Peter</title>
		<link>http://www.pappasontaxes.com/index.php/2009/07/04/new-tax-blog-alert-april15com/comment-page-1/#comment-1797</link>
		<dc:creator>Peter</dc:creator>
		<pubDate>Sun, 05 Jul 2009 21:12:48 +0000</pubDate>
		<guid isPermaLink="false">http://blog.pappastax.com/?p=6769#comment-1797</guid>
		<description>Bruce,

You have read my post incorrectly on two accounts.

1. I never said CPAs are expert preparers. I merely said that given a choice between an unenrolled preparer and a preparer who happens to have a CPA license, it makes sense to choose the latter. Independent studies and Nina Olson&#039;s findings agree with my position;

2.  I did not say that unenrolled preparers are incapable of preparing returns. In fact I said the opposite. Some of the best preparers out there are unenrolled preparers. Probably you and Robert fall into that category.

The good unenrolled preparers should do everything possible to either become CPAs or become IRS Enrolled Agents.</description>
		<content:encoded><![CDATA[<p>Bruce,</p>
<p>You have read my post incorrectly on two accounts.</p>
<p>1. I never said CPAs are expert preparers. I merely said that given a choice between an unenrolled preparer and a preparer who happens to have a CPA license, it makes sense to choose the latter. Independent studies and Nina Olson&#8217;s findings agree with my position;</p>
<p>2.  I did not say that unenrolled preparers are incapable of preparing returns. In fact I said the opposite. Some of the best preparers out there are unenrolled preparers. Probably you and Robert fall into that category.</p>
<p>The good unenrolled preparers should do everything possible to either become CPAs or become IRS Enrolled Agents.</p>
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	<item>
		<title>By: Bruce</title>
		<link>http://www.pappasontaxes.com/index.php/2009/07/04/new-tax-blog-alert-april15com/comment-page-1/#comment-1796</link>
		<dc:creator>Bruce</dc:creator>
		<pubDate>Sun, 05 Jul 2009 19:12:21 +0000</pubDate>
		<guid isPermaLink="false">http://blog.pappastax.com/?p=6769#comment-1796</guid>
		<description>You are correct; I agree a CPA is probably the expert at keeping books and records.

However, being an expert bookkeeper does not make an expert tax preparer.

I am aware greatly that “unenrolled preparer” is NOT a designation. What I read into your words are that because one does not have a designation they aren&#039;t capable because they have no one to answer to.  

This just isn&#039;t so.

What higher regulatory body is there in taxation than the IRS? 

Does Circular 230 not regulate us as well as a CPA or other prepares with title such as Attorneys.
Enrolled agents, Enrolled actuaries?

This just isn&#039;t so.

What higher regulatory body is there in taxation than the IRS? 
Does Circular 230 not regulate us as well as a CPA?</description>
		<content:encoded><![CDATA[<p>You are correct; I agree a CPA is probably the expert at keeping books and records.</p>
<p>However, being an expert bookkeeper does not make an expert tax preparer.</p>
<p>I am aware greatly that “unenrolled preparer” is NOT a designation. What I read into your words are that because one does not have a designation they aren&#8217;t capable because they have no one to answer to.  </p>
<p>This just isn&#8217;t so.</p>
<p>What higher regulatory body is there in taxation than the IRS? </p>
<p>Does Circular 230 not regulate us as well as a CPA or other prepares with title such as Attorneys.<br />
Enrolled agents, Enrolled actuaries?</p>
<p>This just isn&#8217;t so.</p>
<p>What higher regulatory body is there in taxation than the IRS?<br />
Does Circular 230 not regulate us as well as a CPA?</p>
]]></content:encoded>
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	<item>
		<title>By: Peter</title>
		<link>http://www.pappasontaxes.com/index.php/2009/07/04/new-tax-blog-alert-april15com/comment-page-1/#comment-1795</link>
		<dc:creator>Peter</dc:creator>
		<pubDate>Sun, 05 Jul 2009 17:28:15 +0000</pubDate>
		<guid isPermaLink="false">http://blog.pappastax.com/?p=6769#comment-1795</guid>
		<description>Bruce, 

My detailed response to your post will be published tomorrow morning.

Read my post again. Here is what I said:

&quot;All but the militantly nefarious and hopelessly deluded will concede that CPAs are experts at keeping books and records. There simply is no higher accounting designation.&quot;

You can&#039;t possibly disagree with this statement?

Are you saying that a CPA is NOT an expert in accounting?

If you are (and I pray you aren&#039;t), then you&#039;re indeed either nefarious or deluded.

Bruce, &quot;unenrolled preparer&quot; is NOT a designation.

It simply means that the preparer is neither a CPA, lawyer or IRS Enrolled Agent.

It is a negative or non-designation meaning anyone who is NOT licensed, has not been required to demonstrate a minimal level of ability or knowledge and does not have to comply with a regulatory body&#039;s professional standards.

This is stunning that you cannot concede something as basic as this logical formulation:

An unenrolled preparer with a CPA license is, presumptively, a better trained and educated preparer than,

Just an unenrolled preparer.</description>
		<content:encoded><![CDATA[<p>Bruce, </p>
<p>My detailed response to your post will be published tomorrow morning.</p>
<p>Read my post again. Here is what I said:</p>
<p>&#8220;All but the militantly nefarious and hopelessly deluded will concede that CPAs are experts at keeping books and records. There simply is no higher accounting designation.&#8221;</p>
<p>You can&#8217;t possibly disagree with this statement?</p>
<p>Are you saying that a CPA is NOT an expert in accounting?</p>
<p>If you are (and I pray you aren&#8217;t), then you&#8217;re indeed either nefarious or deluded.</p>
<p>Bruce, &#8220;unenrolled preparer&#8221; is NOT a designation.</p>
<p>It simply means that the preparer is neither a CPA, lawyer or IRS Enrolled Agent.</p>
<p>It is a negative or non-designation meaning anyone who is NOT licensed, has not been required to demonstrate a minimal level of ability or knowledge and does not have to comply with a regulatory body&#8217;s professional standards.</p>
<p>This is stunning that you cannot concede something as basic as this logical formulation:</p>
<p>An unenrolled preparer with a CPA license is, presumptively, a better trained and educated preparer than,</p>
<p>Just an unenrolled preparer.</p>
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	</item>
	<item>
		<title>By: Bruce</title>
		<link>http://www.pappasontaxes.com/index.php/2009/07/04/new-tax-blog-alert-april15com/comment-page-1/#comment-1794</link>
		<dc:creator>Bruce</dc:creator>
		<pubDate>Sun, 05 Jul 2009 14:55:31 +0000</pubDate>
		<guid isPermaLink="false">http://blog.pappastax.com/?p=6769#comment-1794</guid>
		<description>Agreeably &quot;CPAs have demonstrated the knowledge and ability to handle numbers and maintain proper books and records.&quot; this doesn&#039;t include tax rules and regulations, or tax law.

I am confused. Why I should prove my accounting ability?

Is it possible that mentioning concern about the increase in negligence and outright fraud amongst CPAs might have reduced her credibility? 

No that is just militantly nefarious and hopelessly deluded.

From IRS Publication Circular 230
10.2 Definitions.
 (1) Attorney means any person who is a member in good standing of the bar of the highest court of any state, territory, or possession of the United States, including a Commonwealth, or the District of Columbia.

(2) Certified public accountant means any person who is duly qualified to practice as a certified public accountant in any state, territory, or possession of the United States, including a Commonwealth, or the District of Columbia.

(4) Practice before the Internal Revenue Service comprehends all matters connected with a presentation to the Internal Revenue Service or any of its officers or employees relating to a taxpayer’s rights, privileges, or liabilities under laws or regulations administered by the Internal Revenue Service. Such presentations include, but are not limited to, preparing
and filing documents, corresponding and communicating with the Internal Revenue Service, rendering written advice with respect to any entity, transaction, plan or arrangement, or other plan or arrangement having a potential for tax avoidance or evasion, and representing a client at conferences, hearings and meetings.

(5) Practitioner means any individual described in paragraphs (a), (b), (c), (d) or (e) of §10.3.

§ 10.3 Who may practice.
(a) Attorneys. 
(b) Certified public accountants. 
(c) Enrolled agents. 
(d) Enrolled actuaries.
(e) Enrolled retirement plan agents

(f) Others. Any individual qualifying under paragraph §10.5(d) or §10.7 is eligible to practice before the Internal Revenue Service to the extent provided in those sections.

§ 10.7 Representing oneself; participating in rulemaking; limited practice; special appearances;
and return preparation.

(c) Limited practice —
	(1)
		(viii) An individual who prepares and signs a taxpayer’s tax return as the preparer, or who prepares a tax return
(2) Limitations. 
(iii) An individual who represents a taxpayer under the authority of paragraph (c)(1) of this section is subject, to the extent of his or her authority, to such rules of general applicability regarding standards of conduct and other matters as the Director of the Office of Professional Responsibility prescribes.

(e) Preparing tax returns and furnishing information.
Any individual may prepare a tax return, appear as a witness for the taxpayer before the Internal Revenue Service, or furnish information at the request of the Internal Revenue Service or any of its officers or employees.

Publication 470, Limited Practice Without Enrollment (PDF) explains Revenue Procedure 81-38, which prescribes the standards of conduct, scope of authority, and the circumstances under which an individual preparer of tax returns may exercise the privilege of limited practice as the taxpayer&#039;s representative before the IRS, without enrollment and pursuant to section 10.7(a)(7) of Treasury Department Circular No. 230

As you can see unenrolled preparers are regulated just as Any other practitioner by Circular 230</description>
		<content:encoded><![CDATA[<p>Agreeably &#8220;CPAs have demonstrated the knowledge and ability to handle numbers and maintain proper books and records.&#8221; this doesn&#8217;t include tax rules and regulations, or tax law.</p>
<p>I am confused. Why I should prove my accounting ability?</p>
<p>Is it possible that mentioning concern about the increase in negligence and outright fraud amongst CPAs might have reduced her credibility? </p>
<p>No that is just militantly nefarious and hopelessly deluded.</p>
<p>From IRS Publication Circular 230<br />
10.2 Definitions.<br />
 (1) Attorney means any person who is a member in good standing of the bar of the highest court of any state, territory, or possession of the United States, including a Commonwealth, or the District of Columbia.</p>
<p>(2) Certified public accountant means any person who is duly qualified to practice as a certified public accountant in any state, territory, or possession of the United States, including a Commonwealth, or the District of Columbia.</p>
<p>(4) Practice before the Internal Revenue Service comprehends all matters connected with a presentation to the Internal Revenue Service or any of its officers or employees relating to a taxpayer’s rights, privileges, or liabilities under laws or regulations administered by the Internal Revenue Service. Such presentations include, but are not limited to, preparing<br />
and filing documents, corresponding and communicating with the Internal Revenue Service, rendering written advice with respect to any entity, transaction, plan or arrangement, or other plan or arrangement having a potential for tax avoidance or evasion, and representing a client at conferences, hearings and meetings.</p>
<p>(5) Practitioner means any individual described in paragraphs (a), (b), (c), (d) or (e) of §10.3.</p>
<p>§ 10.3 Who may practice.<br />
(a) Attorneys.<br />
(b) Certified public accountants.<br />
(c) Enrolled agents.<br />
(d) Enrolled actuaries.<br />
(e) Enrolled retirement plan agents</p>
<p>(f) Others. Any individual qualifying under paragraph §10.5(d) or §10.7 is eligible to practice before the Internal Revenue Service to the extent provided in those sections.</p>
<p>§ 10.7 Representing oneself; participating in rulemaking; limited practice; special appearances;<br />
and return preparation.</p>
<p>(c) Limited practice —<br />
	(1)<br />
		(viii) An individual who prepares and signs a taxpayer’s tax return as the preparer, or who prepares a tax return<br />
(2) Limitations.<br />
(iii) An individual who represents a taxpayer under the authority of paragraph (c)(1) of this section is subject, to the extent of his or her authority, to such rules of general applicability regarding standards of conduct and other matters as the Director of the Office of Professional Responsibility prescribes.</p>
<p>(e) Preparing tax returns and furnishing information.<br />
Any individual may prepare a tax return, appear as a witness for the taxpayer before the Internal Revenue Service, or furnish information at the request of the Internal Revenue Service or any of its officers or employees.</p>
<p>Publication 470, Limited Practice Without Enrollment (PDF) explains Revenue Procedure 81-38, which prescribes the standards of conduct, scope of authority, and the circumstances under which an individual preparer of tax returns may exercise the privilege of limited practice as the taxpayer&#8217;s representative before the IRS, without enrollment and pursuant to section 10.7(a)(7) of Treasury Department Circular No. 230</p>
<p>As you can see unenrolled preparers are regulated just as Any other practitioner by Circular 230</p>
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