Comment on FR Doc # 2011-26247

The change in Prop Reg Sec 1.6695-2(b)(4)(ii) would require retention of documents for 3 years from the due date of the return (without extension) or the date the return or claim for refund was filed, whichever is later. When a tax return preparer prepares a paper return and provides it to the taxpayer to file, the preparer has no way of knowing when, or if, the return is filed. Therefore, the new regulation would effectively require an open-ended retention period in these cases. I suggest that a finite date be established to resolve this issue.