The New Palindrome - OPR-RPO | AccountingWEB

The New Palindrome - OPR-RPO

Did you attend IRS's webinar yesterday about the new structure in the Office Of Professional Responsibility, headed by Karen Hawkins and the NEW Return Preparer Office, headed by Dave Williams?

arrow PTIN Requirements for Tax Professionals
arrow Circular 230
arrow Circular 230 Tax Professionals
arrow Frequently Asked Questions


(note: palindrome - do you know what that is? )

Lots of fun. We got an overview of how they split up responsbilities and staff - and how this will affect us all

 CPAs, EAs, attorneys, and other circular 230 practitioners - and the new designation, Registered Tax Return Preparers.

Their video should be up in about a month.

Meanwhile, if you want some of the background information, just visit these links:

Here are some RAW notes I took during the webinar:

Karen told the story of the history of Circular 230 - how it was based on law right after the Civil War and predates even the US Tax Code. (TaxMama Note: That means EAs' authority predates the Tax Code, too, since Enrolled Agents were enrolled to verify war reparation. EAs were meant to protect folks, and the government coffers, after the Civil War, from carpetbaggers, trying to rip off the system.)

David and Karen are working closely together, in perfect concert. They have logically agreed on a split of responsibilities within Circular 230.

David is essentially responsible for Circ 230 Subpart A & B & C

David and his team are responsible for all the testing, registration and related issues for both EAs and RTRP, the PTIN registration and database.
Karen - is essentially responsible for Circ 230 Subpart C & D
Karen oversees non-preparers – Representatives, tax controversy
She can do more than disbar – but impose monetary sanctions, including 100% of money compensation or anticipates receiving as compensation.
25 of Karen’s personnel went to David –
·        all involved in Enrollment process.
·        Plus 4 or 5 others
Karen’s down from about 56 to about 30.
She will rebuild and hire folks with focus on conduct – attorneys, paralegals. 
OPR is a TOP PRIORTY for commissioner to be properly resourced and funded.
This program is not a ‘flavor of the month’ (despite what some people inside IRS think…as well as people outside IRS.) Even if there is a new Commissioner…this programs will continue.

Some topics Karen covered are
  •  conflict of interest issues,
  • preparer regulation
  • Complaints about Preparers. Sometimes, rather than disbarment, “you need a 6-month rest, or time-out” . OPR just listens to the issues and talk to us. She can’t impose discipline – she can turn it over to Counsel. Duties/obligations sections of Circ 230 go to OPR,

Questions to
Question - Are you concerned about this program being affected by budget cuts?
David says - Benefit of the user fee – the project is self-supporting and not subject to budget cuts
Question - Retired CPAs, do they need to take the RTRP exam?
David - If they are still maintaining their license? No. If not, if they have let their license lapse – yes they must test.
 Karen - Disbarred CPAs must take the RTRP exam.
Question - I’ve never done tax returns before. But want to in 2012. Can I just get my PTIN now – and wait to take the test until 2013.
David says yes.
Karen says, yes…but please don’t just go out and buy some software off the shelf and start going into business doing tax returns without education or training, or you just might find yourself, in a different part of the system, being referred to my office because you haven’t prepared returns correctly.
Question - Callers are having difficulty getting through on the phone lines. Keep getting busy and told to call back later.
David says he calls several times a day to test the line. He calls and gets through within about 5 minutes. Except at lunch – the lines are busier.
Question -Trying to get a PTIN, but have been filing jointly and all IRS correspondence is under my husband’s SSN.
David – this is an authentication issue, to avoid identity theft. The electronic matching system had a glitch, programmed for a 1950’s society. If you used a different last name, you had a problem. That was a little embarrassing. But this was fixed for this year. You should not still be having a problem with that.
Question - I Have a provisional PTIN. When must I get a permanent PTIN? How do I get one?
David – CPAs, EAs, Attorneys have a permanent PTINs. They already qualified. Everyone else – must pass the test before 12/31/13 – that and your filing status and compliance.
 Question -  What happens when a complaint has been filed.
Karen – we will alert the tax pro when we get the complaint and ask for their side of it. We will go back to the original complainant and get more details. Often it’s a he-said; she-said situation that doesn’t really rise to the level of a sanctionable matter.
David – This is an ongoing process, We are listening to your complaints and working to address them.
Karen – My piece of the agency is obligated to make decisions in a manner that is not arbitrary, capricious, unreasonable or unfair (etc). Don’t put us in the position to sanction you by default, by not answering us.


Note: TaxMama®  has submitted information to the new IRS system and has been granted the NEW approved CPE provider status. She is also signed up with NASBA. So look for a whole array of courses and webinars from TaxMama®  - both at one of the TaxMama®   family of sites – and at CPE Link.  New information will be posted in January. We’ve got some exciting material lined up for you!

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Eva Rosenberg, MBA, EA, is the publisher of, and author of the weekly syndicated Ask TaxMama column. She provides answers to tax questions from taxpayers and tax professionals worldwide.

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