Re: 26 CFR Part 300 [REG-116284-11] RIN 1545-BK24
I strongly object to the Department of the Treasury requiring attorneys, certified public accountants, enrolled agents, enrolled retriment plan agents and enrolled actuaries to be fingerprinted in order to prepare tax returns for compensation. As part of the annual licensing process, CPAs must disclose any criminal activity that occurred during the immediate past year. Failure to properly report is cause for suspension of the CPA's license to practice. A hallmark of a profession is the requierment to self regulate. CPAs have done a good job of identifying and eliminating from practice individuals who are unfit to practice public accounting. There is no need to overlay an additional Federal requirement. This is a costly and needless duplication of effort.
Additionally, I am opposed to the requirement to fingerprint non-signing tax return preparers who work directly under the supervision of a CPA. By sigining the tax return, the CPA assumes responsibility for reviewing and approving the tax return for signature by the taxpayer. CPAs can be trusted to properly oversee and supervise their employees. Failure by a CPA to oversee and supervise his employees will result in loss of clients and personal embarassement. A CPA's greatest asset is integrity. Requiring fingerprinting of many hundreds of thousands of non-signing tax return preparers is unnecessary, duplicative, intrusive and expensive.
Comment on FR Doc # 2011-24771
This is comment on Proposed Rule
User Fees: Registered Tax Return Preparer Competency Examination and Fingerprinting Participants, etc.
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