…administrators. As always, we look forward to continuing to work with you on creating a common sense, rigorous oversight framework that protects all taxpayers, levels the industry playing field, and produces more accurate tax returns. Sincerely, Francis X. Degen, EA, USTCP President cc: Steven Miller, Deputy Commissioner for Services and Enforcement Karen Hawkins, Director, Office of Professional Responsibility 1 “Frequently Asked Questions: Testing Requirements, FAQ b1,” posted July 18, 2011, http://www.irs.gov/taxpros/article/0,,id=239683,00.html. 2 Frequently Asked Questions: Testing Requirements, FAQ b7,” http://www.irs.gov/taxpros/article/0,,id=239683,00.html…

…and business taxpayers. EAs adhere to a code of ethics and professional conduct and are required by IRS to take continuing professional education. Like attorneys and certified public accountants, enrolled agents are governed by Treasury Circular 230 in their practice before IRS. Since its founding in 1972, NAEA has been the enrolled agents’ primary advocate before Congress and IRS. NAEA has affiliates and chapters in 42 states. For additional information about NAEA, please go to our website at www.naea.org. 1http://www.house.gov/jct/x-29-07.pdf…

…and business taxpayers. EAs adhere to a code of ethics and professional conduct and are required by IRS to take continuing professional education. Like attorneys and certified public accountants, enrolled agents are governed by Treasury Circular 230 in their practice before IRS. Since its founding in 1972, NAEA has been the enrolled agents’ primary advocate before Congress and IRS. NAEA has affiliates and chapters in 42 states. For additional information about NAEA, please go to our website at www.naea.org. http://www.house.gov/jct/x-29-07.pdf…

…is that the follow-up notices are being sent without respect to information provided in response to the initial correspondence audit itself. In some cases IRS has lost or claims to have never received the response, while in at least one case IRS campus staff has informed an enrolled agent that the 90-day letter may indeed be issued before IRS is able to process the taxpayer’s documentation submission. This EA was advised to file a Tax Court petition! Other enrolled agents…

…probably prevent fraudulent offers, it will certainly prevent earnest taxpayers from making their offers, too. We believe that at the end of the day, taxpayers have a right to have their tax debt compromised. With IRS permitted to wait 24 months to accept an offer, at least until 2010, one of the common concerns is the possibility that IRS may use this new rule to further slow its processing of offers (particularly in the case of taxpayers making monthly ‘good…

…an offer, at least until 2010, one of the common concerns is the possibility that IRS may use this new rule to further slow its processing of offers (particularly in the case of taxpayers making monthly ‘good faith’ payments). A further concern is that some taxpayers plan to borrow to meet their tax obligations (often from family) and such taxpayers would see this plan as a great disincentive to make an offer. After all, does it make sense to borrow…