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The Number And Certified Public Accountant

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Circular 230

In relevance to PTIN number and Certified Public accountants in section 10.3(b). “Any certified public accountant who is not currently under suspension or disbarment from practice before the Internal Revenue Service may practice before the Internal Revenue Service by filing with the Internal Revenue Service a written declaration that the certified public accountant is currently qualified as a certified public accountant and is authorized to represent the party or parties.”

If a California certified public accountant is licensed, but does not have a Social Security number and the Return Preparer Office does not provide the CPA with a PTIN number. There is a conflict between the IRS and RPO policies. It is ironic that a CPA can represent a person before the Internal Revenue Service, but can not prepare income taxes for not having a PTIN number. This is a conflict created by the Register Preparer Office because a Social Security number is not a requirement.

In relation to the Social Security number requirement to obtain a PTIN 10.4(a)-(c) says ”....The Commissioner, or delegate, will grant enrollment.....[to an applicant] who possesses a current or otherwise valid preparer tax identification number or other prescribed identifying number,...”

A current PTIN number or other prescribed tax identification number are requirements for enrollment as an enrolled agent, retirement plan agent, and registered tax return preparer. This section is paraphrasing section

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