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Posted by SMF on January 2, 2008, 8:24 pm
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I have been operating a very small bookkeeping tax return preparation
business out of my home for the past 20 years. I file my business on
Schedule C. I have an inactive CPA license from the state I lived in
over 20 years ago. I do not operate under a CPA title or use it in
anyway, as I shouldn't being inactive and all. I am not required by CA
to do any continuing education etc. to keep it in the inactive state.
I do however attend yearly state and federal update seminars. I have
been approved by the IRS for years to participate as an Authorized IRS
E-file provider. I have always told clients that I could help them
with any IRS issues but could not represent them before the IRS. In 20
years I have never had the need to do anything but help gather
documents and information to substantiate a line item in question.
Here are my concerns, and you may pose others:
- IRS Circular 230 seems to say that "Practice before the IRS"
includes preparing and filing documents. As such it seems I should be
either an attorney, CPA, enrolled agent, or and enrolled actuary. It
would seem, the inactive license wouldn't qualify. Is it possible I
should be taking steps to become an Enrolled agent? Do you see the
possible problem here? - I also am concerned about PSC being a
required form of business for bookkeepers. Is this the case too?
I would really appreciate any guidance possible. I have the fear that
the 200+ very basic tax returns I file yearly could have been done
without the proper authority to do so.
Thanks, Michael
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