Add to ORKGThe purpose of this paper is to propose a new theory of civil liability to hold tax return preparers liable to their clients for tax malpractice, applying to understatements, overstatements, and non-optimal tax advice. This paper discusses the tax return preparer’s (TRPs, both signatory and nonsignatory) current liability to the government and to the client, specifically addressing Circular 230, AICPA rules, state boards of accountancy, federal regulations, and malpractice for professionals. It will then go through several case studies to establish current gaps in malpractice law for TRPs, showing how the government is usually favored in court while clients are not. Ultimately, I will explain a general theory of liability to apply nationall...
The Internal Revenue Service estimates that $56.3 billion was owed by filers of 1987 individual inco...
I. Introduction ... A. Propriety of a Duty to Correct Material Tax Return Errors ... B. Penalty Stru...
Paul J. Lee examines penalties for tax preparers who rely on information provided by clients and dis...
The use of paid tax return preparers has grown steadily. All paid return preparers, including those ...
When people hire an attorney to represent them, they have a guarantee that their attorney passed a b...
This Article addresses the issue of tax preparer oversight. Currently, anyone may prepare a tax retu...
Our income tax system requires that taxpayers report their income annually and assess the correct am...
This Article addresses the issue of tax preparer oversight. Currently, anyone may prepare a tax retu...
Of the 150 million tax returns filed each year, approximately fifty-six percent are prepared with th...
In this article, Drumbl explores return preparer regulation as a policy matter and questions what wo...
Circular 230 sets forth ethical rules that lawyers and CPAs who practice before the IRS must follow....
The insights from the responsive regulation literature present an intriguing model for IRS interacti...
This article considers existing Internal Revenue Code of 1954 provisions which restrict or regulate ...
When collection of unpaid taxes cannot be effected from the person primarily liable for them, the In...
The tax preparer industry is unusual in that it involves the interpretation of an intricate and comp...
The Internal Revenue Service estimates that $56.3 billion was owed by filers of 1987 individual inco...
I. Introduction ... A. Propriety of a Duty to Correct Material Tax Return Errors ... B. Penalty Stru...
Paul J. Lee examines penalties for tax preparers who rely on information provided by clients and dis...
The use of paid tax return preparers has grown steadily. All paid return preparers, including those ...
When people hire an attorney to represent them, they have a guarantee that their attorney passed a b...
This Article addresses the issue of tax preparer oversight. Currently, anyone may prepare a tax retu...
Our income tax system requires that taxpayers report their income annually and assess the correct am...
This Article addresses the issue of tax preparer oversight. Currently, anyone may prepare a tax retu...
Of the 150 million tax returns filed each year, approximately fifty-six percent are prepared with th...
In this article, Drumbl explores return preparer regulation as a policy matter and questions what wo...
Circular 230 sets forth ethical rules that lawyers and CPAs who practice before the IRS must follow....
The insights from the responsive regulation literature present an intriguing model for IRS interacti...
This article considers existing Internal Revenue Code of 1954 provisions which restrict or regulate ...
When collection of unpaid taxes cannot be effected from the person primarily liable for them, the In...
The tax preparer industry is unusual in that it involves the interpretation of an intricate and comp...
The Internal Revenue Service estimates that $56.3 billion was owed by filers of 1987 individual inco...
I. Introduction ... A. Propriety of a Duty to Correct Material Tax Return Errors ... B. Penalty Stru...
Paul J. Lee examines penalties for tax preparers who rely on information provided by clients and dis...