Taxation-Federal Commons^™

The vast majority of federal individual income tax return s are prepared by paid tax return preparers or by taxpayers using consumer tax preparation software. Circular 230 governs practice before the Service by attorneys, certified public accountants, enrolled agents, enrolled actuaries, and enrolled retirement plan agents (collectively, "practitioners" ). Circular 230, however, has not applied to paid tax return preparers who did not fall within any of the categories of practitioners. Various observers, including the National Taxpayer Advocate and consumer advocacy groups, have expressed significant concerns about the lack of regulation of such unenrolled tax return preparers. 1n June 2009, …

These comments are presented on behalf of the Section of Taxation of the State Bar of Texas. The principal drafters of these comments were Robert D. Probasco, Mark Horowitz and Bruce Bemstien. Additional contributors were Val J. Albright, David E. Colmenero, Joel N. Crouch, Brian Dethrow, Kenneth M. Horwitz and Ronald D. Kerridge. The Committee on Government Submissions (COGS) of the Section of Taxation of the State Bar of Texas has approved these comments. Daniel G. Baucum is the Chair of COGS, and Emily Parker and Daniel J. Micciche reviewed the comments on behalf of COGS.

The following comments are …