Tax Administration: Most Taxpayers Believe They Benefit from Paid Tax Preparers, but Oversight for IRS Is a Challenge
Published: 2003-10-31T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Over 55 percent of the nearly 130 million taxpayers in tax year 2001 used a paid tax preparer. However, using a preparer may not assure that taxpayers pay the least amount due. Last year, GAO estimated that as many as 2 million taxpayers overpaid their 1998 taxes by $945 million because they failed to itemize deductions and half of these used preparers. GAO was asked to (1) obtain the views of taxpayers about paid preparers and examples of preparer performance including any problems and (2) describe the Internal Revenue Service's (IRS's) oversight of problem preparers; the challenges facing IRS in dealing with problem preparers, especially the Office of Professional Responsibility; and the efforts to address those challenges. To obtain the views of taxpayers who used preparers, GAO surveyed a national representative sample of taxpayers.
section_title: What GAO Found
paragraphs: GAO estimates that most of the taxpayers who used a paid preparer believe they benefited from doing so. Many taxpayers told us they believed they would have great difficulty filling out their own tax forms because they do not understand their filing requirements. At the same time, some taxpayers are poorly served when paid preparers make mistakes, causing taxpayers to over-or underpay their taxes or pay for services, such as short-term loans called Refund Anticipation Loans (RALs), without understanding their costs and benefits. The evidence available does not allow a precise estimate of the extent of problems caused by paid preparers, but nothing suggests that the percentage of taxpayers affected is large. Nevertheless, even a small percentage of the over 72 million taxpayers who used paid preparers in 2001 translates into millions of taxpayers who are potentially adversely affected. IRS has several offices responsible for taking action against problem paid preparers, including the newly formed Office of Professional Responsibility. These offices sanction preparers for violating standards of conduct; assess monetary penalties for violating tax laws when preparing returns; monitor and, if justified, sanction problem preparers offering electronic filing and RALs; and investigate fraudulent preparer behavior. However, balancing resources devoted to such efforts against those devoted to other IRS priorities is a challenge. In addition to IRS, other federal agencies, state and local governments, and professional organizations have a role in regulating paid preparers. At least two proposals exist to expand IRS's oversight of paid preparers. Consideration of such proposals is complicated by the difficulty of developing reliable estimates of the number of taxpayers affected by problem preparers or the effectiveness of the actions taken against them.

section_title: Letter
paragraphs: Filing a correct tax return can be a daunting task for taxpayers. Many taxpayers do not understand their filing requirements and would have great  difficulty filling out their tax forms without the assistance of paid  preparers. IRS’s most recent estimates are that in tax year 2001 more than 55 percent of the nearly 130 million individual filers paid someone to  prepare their tax returns, and in tax year 2000, taxpayers paid almost $15  billion for individual tax preparation services. However, using a paid preparer does not always assure that taxpayers will pay the least amount of  taxes that are legally due. For example, last year we estimated that as many  as 2 million taxpayers overpaid their 1998 taxes by $945 million because  they claimed the standard deduction when it would have been more  beneficial to itemize, and half of these taxpayers used a paid preparer.
Concerned that some paid preparers might not be diligent when completing  tax returns, you asked us to (1) obtain the views of taxpayers who used  paid preparers and provide examples of paid preparer performance,  including what is known about the extent of problems caused by paid  preparers and (2) describe IRS’s efforts to prevent, detect, and take action against problem paid preparers; the management challenges facing IRS  offices that interact with paid preparers, especially the Office of  Professional Responsibility; and the efforts to address those management  challenges.
To address the objectives, we surveyed a nationwide random sample of  taxpayers who used paid preparers. While this sample is representative of  all taxpayers who used paid preparers, it has some limitations and must be  interpreted carefully because it is based on taxpayer perceptions.  Taxpayers responding to our survey may not understand the tax laws well  enough to evaluate whether they received quality service from their paid  preparers, resulting in inflated satisfaction levels. In addition, we  conducted in-depth interviews with a smaller judgmental sample of  taxpayers who provided examples of paid preparer performance, but we  were unable to independently verify the facts in the taxpayers’ examples.  We also interviewed paid preparers, representatives of professional  organizations, various IRS officials, and low-income tax clinic directors. We  presented our survey and interview findings at a Finance Committee  hearing on April 1, 2003. In addition, we conducted a review of IRS’s closed  case files on paid preparers investigated for fraud or other misconduct and  reviewed IRS’s paid preparer penalty collection data. A more detailed  discussion of our scope and methodology, including the potential effect of  our taxpayer survey’s 46 percent response rate, may be found in appendix I.
subsections: section_title: Background
paragraphs: Paid preparers aid taxpayers in the completion of their tax returns for a fee.  They range from licensed professionals, such as attorneys, certified public  accountants, and enrolled agents, to those lacking formal training who  complete tax returns part-time. Paid preparers authorized to represent  taxpayers in matters before IRS are called practitioners and include  attorneys, certified public accountants, and enrolled agents. Preparers  work for a variety of enterprises including accounting firms, large tax  preparation services, and law firms. Some are self-employed. IRS estimates  that in 1999 there were 1.2 million paid preparers, although the actual  number is unknown because some paid preparers do not sign the returns  they prepare. The percentage of returns with a paid preparer’s signature  has been steadily increasing over the past 20 years, as shown in figure 1.
Paid preparers provide a variety of tax-related services besides tax  preparation, including tax and estate planning and services that help clients  receive funds quickly, such as electronic filing and RALs.
section_title: Taxpayers Believe They Benefit by Using Paid Preparers but Some Are Poorly Served
paragraphs: Based on projections from our national survey, most taxpayers who used a  paid preparer believe they benefited from doing so and would use a paid preparer in the future. Taxpayer surveys and studies of returns suggest that some taxpayers are poorly served by their paid preparers, but they do not  allow a very precise estimate of the extent of the problem.
subsections: section_title: Most Taxpayers Believe They Benefit From Using Paid Tax Preparers
paragraphs: Based on projections from our national survey, most taxpayers who used a  paid preparer believe they benefit from doing so. We estimate that 77  percent of the taxpayers who used a paid preparer in 2002 were very or  generally confident that they did not pay more in taxes than was legally  required, as shown in figure 2, and that 87 percent would use one again in  the future. These data suggest that paid tax preparers are providing  needed services to taxpayers.
The results of our taxpayer survey must be interpreted carefully—it is  based on taxpayer perceptions, and taxpayers may not understand the tax  laws well enough to evaluate the performance of their paid preparers. For  example, most of the taxpayers we talked to in-depth said they used a paid  preparer because they found IRS tax forms and documents too  complicated or they were confronting an unusually complicated tax  situation. If taxpayers lack the technical expertise needed to identify  preparer errors, their survey responses may underestimate the extent of  problems caused by paid preparers.
With that caveat in mind, taxpayers in our nationwide survey said that their  preparers did sufficient probing or took other steps to ensure an accurate  return. We estimate that about 91 percent of taxpayers believe their  preparers had enough information about their personal circumstances to  accurately prepare their tax returns. We also estimate that 88 percent of  taxpayers using paid preparers were asked for supporting documentation.  Most of the preparers we talked to said they ask their clients to provide  documentation to support claimed income, deductions, and credits, such  as W-2 forms from employers or 1099 forms from financial institutions, to  ensure the accuracy and completeness of the information reported on  returns. In addition, paid preparers are required by law to take certain steps  when filling out returns for their clients, including signing the return and  giving their clients copies of the completed returns. We estimate that the  vast majority of taxpayers who used a paid preparer in 2002 were provided  a signed copy of their return, as shown in figure 3.
Taxpayers choose to use paid preparers for a variety of reasons. As already  noted, many of the taxpayers we interviewed in-depth told us they used a  paid preparer because they did not understand the tax laws. According to  the National Taxpayer Advocate, many taxpayers rely upon the expertise of  a paid preparer to complete their returns since they are faced with a  complex set of tax laws and a multitude of requirements for deductions,  exemptions, and credits. One taxpayer, for example, said she began using a  paid preparer 9 years ago to help her with estate tax issues following the  death of her father because she needed help from a tax professional in  dealing with complicated estate tax issues. Other taxpayers said they  lacked the time or patience to complete their returns on their own. For  example, a mother of four who operates her own business part-time and is  finishing her degree at night said she simply does not have the time to do  her own taxes. Other taxpayers stated that they paid someone to prepare  their taxes in hopes of obtaining a larger and/or quicker refund.
Some of the paid preparers we spoke to agreed that educating taxpayers  about the tax laws is an important component of their practice. For  example, one preparer who works primarily with immigrants said he and  his staff spend considerable time explaining to their clients that paying  taxes is part of the civic responsibilities they assumed in immigrating to  this country. Other preparers told us they often have to educate taxpayers  on more complex concepts, such as computing the basis (the investment  made in a property) to determine how much of a real estate sale would be  taxable. Another preparer told us he found that a taxpayer had overpaid his  taxes by more than $6,200 over a 3-year period because the taxpayer had  overlooked earned income and child tax credits. Still another preparer told  us how he helped a taxpayer receive a refund in excess of $19,000 when he  found out that the taxpayer, who had moved twice in less than 2 years, had  missed out on deductions for moving expenses due to job relocations.
section_title: Some Taxpayers Are Poorly Served by Paid Preparers
paragraphs: When paid preparers make mistakes or exhibit other problematic behavior,  the consequences for taxpayers may be significant. Examples provided by  low-income tax clinicrepresentatives and paid preparers include:
A taxpayer who overpaid his taxes over a period of years by roughly  $3,500 to $5,000. The taxpayer had received notices for several years  from IRS stating that he may be eligible for the Earned Income Credit  (EIC). Each year, he took the notices to his preparer, but the preparer  took no action.
One preparer told his elderly client to provide him with the checks to  make her quarterly estimated payments. Although he claimed these  payments on the client’s tax return, he never gave the checks to IRS—he  kept them for himself. After receiving notices from IRS, the taxpayer  visited the paid preparer who told her that IRS must have made a  mistake. The preparer was sent to jail.
Another preparer incorrectly advised a married couple with two  children to each file separately as head of household so that they could  claim two EICs. The couple ended up owing taxes, interest, and  penalties.
A paid preparer let a taxpayer file for the EIC for 2 years although the  taxpayer lacked the appropriate documentation and was ineligible for  the credit. The taxpayer received a tax refund he was not entitled to  receive, resulting in a tax liability of $3,300.
As with all anecdotal evidence, these examples are not necessarily  representative of the kinds of problems taxpayers encounter when dealing  with problematic paid preparers. Also, taxpayers may have contributed to  these problems by either providing incomplete information to their  preparers or being actively complicit in avoiding taxes that are legitimately  owed.
In addition to over- or underpaying their taxes, IRS officials and others told  us that sometimes taxpayers are poorly served by paying for services that  accelerate the receipt of refunds, including RALs. The primary benefit of  RALs is that they allow clients to receive funds quickly, sometimes in just a  few minutes, rather than the 10 days it typically takes taxpayers who file  electronically to receive their tax refunds. The ability to quickly receive  funds makes RALs appealing to low-income taxpayers who often want or  need their refund quickly. In addition, as the National Taxpayer Advocate  pointed out in the fiscal year 2002 Annual Report to Congress, many low- income clients who lack bank accounts find that RALs are the only way to  electronically file a return and receive their refunds quickly. For these and  other reasons, RALs are becoming more popular. Based on IRS data, the  National Consumer Law Center estimates that 12.1 million RALs were  taken out in 2001, up from 10.8 million in 2000.
Although this suggests that many taxpayers find value in using RALs, IRS  officials and others have raised concerns about whether taxpayers are fully  aware of the costs involved and their tax filing alternatives. For example, a  recent New York City investigation found that some paid preparers fail to  disclose the costs of RALs and the availability of alternatives to the loans.The investigation found that only 27 of the 43 preparers visited mentioned  the annual percentage rate and other fees associated with RALs. New York  City’s investigation also found that electronic filing was not strongly  publicized as an alternative way for clients to receive their tax refunds  quickly. According to a low-income tax clinic director, many paid preparers  fail to fully explain to taxpayers that accepting a RAL carries a certain  risk—if refunds are delayed or denied, taxpayers may be liable for  additional charges and fees. Without clear information about the costs and  risks, taxpayers cannot always weigh the costs against the benefits that  they might receive.
Also, based on information we gathered, fees for RALs and other services  that accelerate the receipt of refunds vary widely. For example, while some  preparers charge nothing for electronic filing services, one preparer we  spoke to (while we were posing as a potential client) said he would charge  us between $210 and $250 to file electronically. Another preparer said he  would charge $174 for a RAL on a $700 refund, which equates to an annual  interest rate of over 900 percent, assuming a loan period of 10 days, while  another preparer quoted us a RAL fee of $130 on a $1,200 refund, which  equates to an annual interest rate of about 400 percent, assuming the same  loan period. These examples are not necessarily representative of all  preparer fees; the exact amounts of preparer fees for accelerated refunds  depend on various individual circumstances, such as the financial  institution the preparer uses to finance the loan and the amount of refund  due.
The RAL fees, when combined with tax preparation fees, may considerably  reduce a taxpayer’s refund. For example, the preparer mentioned above  who quoted a RAL fee of $130 on a $1,200 refund also quoted a tax  preparation fee of $190 in addition to the RAL fee. As shown in figure 4  below, the fees would have reduced the refund by more than 25 percent.
In another example, a low-income tax clinic director informed us of a  disabled taxpayer who was due a refund of $1,230 on a simple return. After  paying various fees, such as return preparation and a RAL, she received a  check from her preparer for $414—about 34 percent of her expected  refund.
section_title: Little Authoritative Evidence Regarding Problematic Paid Preparers
paragraphs: A variety of evidence, including the above examples and our nationwide  survey, shows that some taxpayers are poorly served by their paid  preparers. While this evidence does not allow a precise estimate due to  methodological limitations, none of it suggests that the percentage of  poorly served taxpayers is large. However, even a small percentage of the  more than 72 million taxpayers who used paid preparers in 2001 can  translate into millions of affected taxpayers.
Taxpayer surveys show that some taxpayers had problems with the quality  of the service provided by their paid preparer. Based on the results of our  nationwide survey, we estimate that 5 percent of paid preparer users had  no confidence that they had not overpaid their taxes, and another 7 percent  had little confidence, as shown in figure 2. We also estimate that 3 percent  of paid preparer users did not believe that their preparer had enough  information to accurately complete their return, as shown in figure 2. Our  survey results are similar to a 1997 Consumer Reports nonrandom survey  of 26,000 of its readers, in which 6 percent said they discovered an error  made by their preparers. As discussed earlier, taxpayer survey results need  to be interpreted carefully because they reflect taxpayer perceptions and  may misstate the extent of the problem.
Studies of filed returns also suggest that some paid preparers do not  exercise due diligence in filing returns. For example, we have already  mentioned that last year we estimated that as many as 2 million taxpayers  overpaid their 1998 taxes by $945 million because they claimed the  standard deduction when it would have been more beneficial to itemize,  and half of these taxpayers used a paid preparer. Similarly, a recent report  by the Treasury Inspector General for Tax Administration estimated that  there were approximately 230,000 returns filed by paid preparers where  taxpayers appeared eligible for but did not claim the Additional Child Tax  Credit. In addition, a 2002 IRS study of the EIC for tax year 1999 returns  estimated that some taxpayers claimed about $11 billion more than they  were entitled to while others claimed $710 million less than they were  entitled to.The IRS reported that paid preparers filed more than 65  percent of all EIC returns. None of these studies tried to determine how  many errors were the fault of the preparer and how many were the fault of  the taxpayer. However, based on our earlier examples of paid preparer  performance, it seems likely that preparers bear responsibility for at least  some of the over- or underpayments. Taxpayers could be at fault if they  provide the preparer with incorrect information.
section_title: IRS and Others Act Against Problem Paid Preparers, but Balancing Taxpayer Protection Against Other Priorities Is a Challenge
paragraphs: Several IRS offices have responsibility for problem paid preparers, but  balancing resources devoted to taxpayer protection with resources  devoted to other priorities is a challenge. Proposals have been made for  expanding IRS’s oversight of the paid preparer industry. Consideration of  such proposals is complicated by a lack of data on the extent of the  problem and the effectiveness of IRS’s actions and by the involvement of  other agencies, state, and local governments as well as professional  organizations.
subsections: section_title: New Office of Professional Responsibility (OPR) Beginning to Address Problems Overseeing Practioners
paragraphs: The newly formed OPR enforces professional standards for those paid  preparers authorized to represent taxpayers in matters before IRS. These  authorized preparers, called practitioners, include attorneys, certified  public accountants, and enrolled agents.
Treasury Department Circular No. 230 imposes standards of  professionalism and conduct for practitioners and authorizes IRS to  institute proceedings against practitioners who violate the regulations.Depending on the seriousness of the violation, OPR can sanction  practitioners through private reprimand, censure (a public reprimand),  suspension, or disbarment. For example:
As a result of an OPR investigation, OPR accepted a practioner’s offer of  consent to suspension for almost 3 years for violation of the  requirement of due diligence as to accuracy in preparing corporate tax  returns for 3 years. The practitioner underreported income by over  $50,000 in 1 year, and claimed unsubstantiated expenses of over $25,000  in the other 2 years. The practitioner also overstated a real estate tax  deduction by over $30,000 in 1 year.
In another case, a practitioner was disbarred from practice for giving  false or misleading information to IRS. The practitioner signed a power  of attorney as being licensed when the license had not been renewed,  thereby making the practitioner ineligible to practice before IRS.
As part of IRS’s modernization effort, IRS hired an outside management  consulting firm to make high-level recommendations concerning the  staffing, organization, technology, and operating procedures of the Office  of Director of Practice (ODP), the office OPR replaced. Table 1 summarizes  the consultant’s findings.
According to the OPR Director, IRS took the high-level findings of the  consultant’s report and drew on its management and staff’s expertise to  develop a plan to make needed improvements. For example, IRS  reorganized the office, renaming it OPR, and has started to implement  several other changes. As an initial step, OPR contacted various tax  professional organizations in January 2003 and laid out the following  priorities for the balance of 2003: enhance the visibility of OPR internally as well as externally,  increase the capacity and capability of OPR, process the workload in a shorter time frame, ensure that Circular 230 sanctions are applied fairly and consistently,  identify and implement organizational performance measures, and establish and maintain an effective working alliance with the tax  professional organization community.
While IRS has already made some improvements, according to the OPR  Director, the following efforts are on-going: hiring and training a significantly expanded staff of attorneys and  improving and documenting operational practices and procedures; communicating the OPR mission and progress internally and externally  through speaking engagements, newsletters, and Web sites; working with IRS Chief Counsel and Treasury Department Tax Policy  personnel to make beneficial amendments to Circular 230; and maintaining an open door policy with respect to the practitioner  community in order to learn of their concerns and their suggestions.
Also, the OPR director said it is going to take some time to make all the  needed changes. We did not try to assess OPR’s on-going improvements  because some are not yet complete and others are too new to have  produced the desired improvements.
section_title: SB/SE Faces Challenges Balancing Paid Preparer Compliance Actions With Other Enforcement Priorities
paragraphs: IRS’s SB/SE division has responsibility for assessing and collecting  monetary penalties against any paid preparers who do not comply with tax  laws when filing returns. SB/SE assessed about $2.4 million in penalties in  calendar years 2001 and 2002, and collected about $291,000 or 12 percent,  including all or some portion of penalties from 44 percent of the preparers  penalized. According to IRS officials, collecting paid preparer penalties has  not been a priority in the division’s overall collection efforts due to other  higher priority work, such as abusive tax schemes.
According to an SB/SE representative, there are currently no plans for  SB/SE to make collecting paid preparer penalties a priority. The  representative stated that their priorities include abusive tax schemes, and  they cannot afford to make these low dollar paid preparer cases a priority  given their responsibility for addressing billions of dollars in uncollected  taxes. Also, IRS does not currently have a system in place to identify paid  preparer penalties separately from other assessments once a case is  assigned for collection, and to do so would require a labor-intensive  computer programming effort.
However, the monetary amounts of these penalties, which are small  relative to IRS’s other compliance efforts, may not reflect how important  the penalties are as a deterrent to problematic paid preparers. According to  the Internal Revenue Manual, penalty assertion is the key enforcement  vehicle for noncompliant preparers. As mentioned earlier, IRS has no data  on the extent of the problems with paid preparers or how effective its  enforcement efforts are in deterring problematic preparer behavior. In  assessing but not collecting these penalties, IRS may be sending preparers  a mixed message about whether poor performance by preparers will be  tolerated. For example, several paid preparers and low-income tax clinic  officials we interviewed said that IRS was not providing enough paid  preparer oversight and that it should be increased. IRS has made changes  to its fiscal year 2003 compliance program guidance to place a higher  priority on assessing penalties against problem preparers. However,  collecting paid preparer penalties will continue to be part of the regular  collection process because they are not to be given any special treatment  as a priority.
section_title: IRS Monitors Preparers Who Offer Electronic Filing but Has Limited Role in Monitoring RALS
paragraphs: IRS has broad authority to monitor and sanction Electronic Return  Originators (ERO) whom IRS authorizes to file tax returns electronically.  IRS’s monitoring is to ensure ERO compliance with provisions of any  revenue procedures, publications, or notices that govern IRS’s e-file  program, including RALs. Through random and mandatory visits, the ERO  monitoring program offices monitor the activities of EROs to ensure  compliance with IRS’s e-file program and to investigate allegations and  complaints against EROs. In 2001, IRS established a goal of visiting 1  percent of all EROs each year. IRS met its goal in 2002, visiting more than  1,400 EROs and sanctioning 215 of them for violating IRS guidelines. Figure  5 shows the number of EROs visited and sanctions issued by degree of  seriousness, for fiscal year 2002, and for two thirds of fiscal year 2003,  based on the most recent data available through May 2003.
However, while IRS does impose some requirements on paid preparers  offering RALs, its role is limited and the requirements serve in part to  ensure that RALs are presented to taxpayers as loans and not as an  accelerated tax refund. For example, IRS’s Publication 1345 prohibits EROs  from basing their fees on a percentage of the refund amount or computing  their fees using any figure from tax returns.
section_title: CI Division Investigates Criminal and Fraudulent Preparer Behavior
paragraphs: IRS’s CI division investigates paid preparers suspected of criminal or  fraudulent behavior and other related financial crimes. However, according  to CI officials, they have a system using indicators developed from prior  cases to identify and work only the most egregious cases due to overall  resource limitations, leaving some cases unworked. Nevertheless,  according to IRS, CI is increasing its investigations of criminal and  fraudulent paid preparers. For example, according to IRS it more than  doubled the number of paid preparer criminal investigations in 2002  compared to 2001 and experienced a significant increase in the number of  investigations referred for prosecution in the first quarter of fiscal year  2003.
CI officials told us that to prioritize its work, CI identifies and investigates  the most egregious criminal behavior using a fraud ranking system that  determines which preparers should be investigated. Officials said the  ranking is based on information developed from individual returns  provided by fraud detection centers. Fraud detection centers are CI offices  collocated at IRS campuses that attempt to detect fraud by scanning paper  and electronic returns. The system ranks preparers by the number of  suspected fraudulent filed returns by applying criteria that have proven in  the past to be successful in prosecution of fraud cases. However, as  mentioned earlier, IRS has no data on the extent of the problem with paid  preparers, including those who are fraudulent, or the effectiveness of CI’s  deterrent actions against them.
Two programs provide much of the organizational framework for CI’s  actions against criminal paid preparer behavior. The division’s Return  Preparer Program identifies and investigates criminal paid preparers while  the Questionable Refund Program identifies fraudulent tax returns. Once  identified, the program stops payment on fraudulent tax refunds and refers  fraudulent tax schemes to CI field offices for further investigation. Figure 6  shows that in 2001 and 2002, CI evaluated 574 referrals of possible criminal  paid preparer behavior and initiated 395 criminal investigations against  paid preparers.
According to CI, criminal paid preparer behavior varies. Some criminal  preparers create false forms such as W-2s and file returns on behalf of  deceased taxpayers. Others buy social security numbers and the names of  dependents from taxpayers with multiple children in order to allow others  to claim dependent related tax credits, such as the EIC. According to CI  officials, most criminal preparers are investigated for aiding and abetting a  false tax return. For example, during 2001 to 2002, more than 91 percent of  CI’s initiated investigations against paid preparers involved preparers who  helped prepare false or fraudulent tax returns. One investigation resulted in  a preparer pleading guilty for assisting in the preparation of false tax  returns and sentenced to 38 months in prison and assessed a $10,000 fine.  The preparer owned and operated a tax preparation business and among  her criminal activities regularly advised clients to claim fraudulent tax  credits for dependents and child care, even though the clients had no  dependents. The preparer’s actions from 1997 to mid-2000 resulted in a loss  to the Treasury of between $1.5 and $2.5 million. From 2001 to 2002, CI  investigations resulted in the indictment and sentencing of 134 paid  preparers, of which 119 were incarcerated.
Anecdotally, several preparers we spoke to stated that publishing examples  of convictions against preparers may help deter future criminal preparer  behavior. However, IRS does not have quantitative information about the  size of the problem with paid preparers or the extent to which convictions  against paid preparers are a deterrent to other preparers. Information on  deterrence would be difficult, perhaps impossible to develop.
section_title: Others Believe More IRS Oversight Is Needed
paragraphs: While IRS provides some oversight of paid preparers, others believe that it  should provide additional oversight. The Low Income Taxpayer Protection  Act of 2003, S. 685 proposed in the 108th Congress, would require the  licensing and registration of paid preparers and RAL providers. The  proposal would also require all preparers to abide by the rules of conduct  that currently govern practitioners and contains provisions aimed at  discouraging the use of RALs, including regulating the fees charged for  RALs.
The National Taxpayer Advocate recommended a similar proposal  requiring the registration of paid preparers in her 2002 Annual Report to  Congress. The proposal would require paid preparers to be registered with  IRS, pass a certification examination, and maintain annual educational  requirements. In a previous report to the Congress, the National Taxpayer  Advocate stated that while paid preparers are subject to monetary  penalties if they prepare returns negligently, many preparers are not  subject to standards of conduct, licensed by any state regulatory agency, or  required to participate in continuing education programs. Thus, according  to the Advocate, the only course of action that can be taken to enjoin a paid  preparer is the initiation of a civil action by the Secretary of the Treasury  against the preparer in A District Court of the United States. According to  the Advocate, such action is costly, time consuming, and leaves  questionable income tax preparers free to remain in business and  potentially harm taxpayers if they continue to prepare income tax returns  during the legal process of the civil action.
Some of the paid preparers and officials from low-income tax clinics and  professional organizations we interviewed said that IRS could provide  additional oversight of paid preparers, although several said that it would  be difficult for IRS to undertake such efforts. Several of the preparers we  interviewed said that IRS’s current oversight of paid preparers needed  improvement and most of the paid preparers, low-income tax clinics, and  professional organizations we interviewed told us they supported the  licensing or registration of paid preparers as a way to provide additional  oversight of paid preparers. For example, one preparer said he felt paid  preparer oversight was not in IRS’s order of priorities and that paid  preparers should be licensed so that IRS could enforce education and  conduct standards. Others told us that IRS should impose a registration or  licensing requirement on paid preparers although some expressed  reservations. For example, a representative from the National Society of  Accountants said that it would be an arduous task for IRS to create a  system to license hundreds of thousands of people and then set up the  mechanisms to discipline them. Officials from a low-income tax clinic also  expressed concerns, saying that such a proposal may increase the cost of  tax preparation by reducing the supply of available preparers.
Any consideration of whether to change IRS’s responsibilities for  overseeing paid preparers would likely take into account several factors.  One, obviously, is the benefits and costs to taxpayers who use paid  preparers. However, as highlighted in this report, data are lacking about the  extent of problematic paid preparer behavior and the effectiveness of  existing IRS actions, which makes it difficult to assess the tradeoff between  benefits and costs. Another factor is that regulating the paid preparer  industry, a private sector industry, is a form of consumer protection. IRS’s  major functions, which include processing tax returns, responding to  taxpayer questions, and enforcing compliance with the tax laws, give it  little experience in providing consumer protection. Still another factor is  the implication for IRS resources. Recently we have reported on declines in  IRS’s enforcement programs, including declines in resources allocated to  those programs. We have also reported that needs in other IRS programs  have often been met at the expense of resources devoted to enforcement.
section_title: IRS Is Not Alone in Providing Some Preparer Oversight
paragraphs: Any consideration of whether to increase IRS paid preparer oversight or  consumer protection must also recognize that IRS is not alone in providing  such oversight. Other federal agencies, such as the Federal Trade  Commission (FTC), state and local governments, and professional  organizations engage in efforts to prevent, detect, and take action against  problem paid preparers. For example, FTC has taken action against paid  preparers pursuant to its authority to enforce the provisions of the Federal  Trade Commission Act. FTC’s primary mission is to protect consumers by  enforcing federal consumer protection laws that prevent fraud, deception,  and unfair business practices. This protection extends to taxpayers using  paid preparers for tax preparation and other related services.
In addition, at least six states and one city have laws that provide paid  preparer oversight or consumer protection regarding RALs. These laws  range from requiring registering or licensing of paid preparers to requiring  disclosure statements for RALs. For example, the City of New York  requires a separate disclosure statement for RAL agreements that must be  provided in English or Spanish. New York City’s law also requires paid  preparers to provide an oral explanation of the law’s required written  disclosure in language understood by the taxpayer. In addition to  government entities, professional organizations, such as the American  Institute of Certified Public Accountants and the American Bar  Association, also impose general standards of conduct on the actions of  their members, including those representing taxpayers before the IRS and  preparing tax returns. We did not attempt to identify all federal, state, and  local governments or professional organizations that have a paid preparer  or RAL oversight role in addition to IRS. Table 3 shows examples of some  tax preparation and RAL oversight in addition to that provided by IRS.
Three of these seven oversight efforts shown in the table above were  passed or enacted within the past year. To date, none of the state or local  governments responsible for the efforts has evaluated the effectiveness of  these efforts. The absence of such data further complicates any  consideration about changing IRS’s role. Without data, IRS management  cannot determine how much these other government entities will provide  paid preparer oversight or consumer protection.
section_title: Concluding Observations
paragraphs: Paid tax preparers are critical to the functioning of our tax system. Many  taxpayers do not understand their filing requirements and would have great  difficulty filling out their tax forms without the assistance of paid  preparers.
While most taxpayers may receive quality services from their preparers,  problematic behavior by some preparers raises the question of whether IRS  should be more active in overseeing paid preparers. Since paid tax  preparation is a private sector industry, this can be viewed as a question  about the extent to which the nation’s tax administrator ought to be  involved in consumer protection. On the one hand, the complexity of the  tax code is at least partly responsible for the existence of the paid tax  preparation industry. As a consequence, IRS might be viewed as properly  having some responsibility for oversight of the industry. On the other hand,  IRS’s mission is tax administration and the agency may not have the  expertise or the regulatory culture for successfully carrying out consumer  protection responsibilities. In addition, unless given a budget increase IRS  would have to divert resources from other priorities in order to carry out  expanded industry oversight responsibilities. In recent years IRS has often  met such resource needs by decreasing staffing of its enforcement  activities.
At least two proposals exist for legislative action, one from the Taxpayer  Advocate and the other, the Low Income Taxpayer Protection Act of 2003,  S. 685, proposed in the108th Congress. Unfortunately, there is not much  reliable information about the tradeoffs associated with changing IRS’s  role. Examples of problematic preparer behavior are easy to find but  reliable estimates of the number of taxpayers affected by the problems do  not exist and would be difficult, perhaps impossible, to develop. Such data  would be needed to properly evaluate proposals for changing IRS’s role.  While the federal government and some state and local governments have  taken actions intended to address problematic preparer behavior, the  effectiveness of the actions is not known. Because making decisions about  IRS’s role is a policy matter and because data are not available to determine  the efficacy of IRS’s current oversight efforts, whether to expand IRS’s role  in ensuring taxpayers receive quality service from paid preparers is a  judgment that Congress and IRS management must make. We are not  making recommendations in this report.
section_title: Agency Comments and Our Evaluation
paragraphs: The Commissioner of Internal Revenue provided written comments on a  draft of this report in an October 28, 2003, letter, which is reprinted in  appendix III. The Commissioner agreed with the information presented in  our report and noted that IRS will continue its efforts to provide oversight  of paid tax preparers and is developing new initiatives to ensure the ethical  responsibility of preparers. These efforts include continuing to develop the  Office of Professional Responsibility, considering changes to Circular 230,  coordinating with professional tax associations, increasing compliance  efforts, forming a multifunctional work group to improve communications  within IRS, and developing a national paid preparer strategy.
The Commissioner said that, based on the information in our report, IRS  will undertake an analysis of whether IRS can take additional steps to  increase the impact of its efforts to assess penalties against paid tax  preparers. In response to our observation that penalties assessed against  paid preparers are not a collection priority, the Commissioner noted, and  we agree that preparer penalty cases are included in IRS’s collection  priority system. Our point is that they are not a collection priority because  of their relatively low dollar value and we noted that IRS collected only 12  percent of the penalties assessed in calendar years 2001 and 2002. The  Commissioner commented that it might be a better reflection of IRS’s  collection efforts to point out that during this period, the agency collected  all or some portion of penalties from 44 percent of the SB/SE preparers  who were assessed a penalty and we changed our draft to show the  percentage collected. We were aware that some paid preparers voluntarily  pay the penalties assessed against them but, as indicated by the  Commissioners’ response, more than half of paid preparers paid nothing.  Since uncollected preparer penalties represent about 88 percent of the  value of penalty assessments, we said that IRS may be sending the paid  preparer community a mixed message about whether poor performance by  preparers will be tolerated. At the same time, we recognize that collecting  paid preparer penalties has not been a priority due to other higher priority  work, such as abusive tax schemes.
As agreed with your offices, unless you publicly announce its contents  earlier, we plan no further distribution of this report until 30 days from its  date. At that time we will send copies to the Secretary of the Treasury, the  Commissioner of Internal Revenue, and other interested parties. We will  also make copies available to others on request. In addition, the report will  be available at no charge on the GAO Web site at http://www.gao.gov.
This report was prepared under the direction of Jonda Van Pelt, Assistant  Director. Other major contributors are acknowledged in appendix IV. If you  have any questions about this report, contact me on (202) 512-9110.
section_title: Objectives, Scope, and Methodology
paragraphs: The objectives of this report were to (1) obtain the views of taxpayers who  used paid preparers and provide examples of paid preparer performance,  including what is known about the extent of problems caused by paid  preparers and (2) describe IRS’s efforts to prevent, detect, and take action  against problem paid preparers; challenges facing IRS offices that interact  with paid preparers, especially the Office of Professional Responsibility;  and efforts to address those challenges.
subsections: section_title: Objective 1: Obtaining Taxpayer Views, Examples of Paid Preparer Performance, and What Is Known about the Extent of Problems Caused by Paid Preparers
paragraphs: To obtain the views of taxpayers who used paid preparers about the quality  of service the preparers provided, we conducted (1) a representative  nationwide survey and (2) in-depth interviews with a small judgmental  sample of the individuals who participated in our nationwide survey. We  also searched for studies that talked about the extent of problems caused  by paid preparers.
subsections: section_title: Methodology for the Taxpayer Survey Regarding Use of Paid Preparers
paragraphs: To determine taxpayer views of their paid preparers, we contracted with  the Marist College Institute for Public Opinion of Poughkeepsie, New York  to include our questions at the beginning of their multisubject telephone  survey of the United States conducted between February 5 and 24, 2003.  Interviews were completed with 917 of the estimated 1,996 eligible sampled  individuals for a response rate of 46 percent. The results presented in our  report are based on the 429 interviews with respondents who reported they  paid someone to prepare their federal personal tax returns for their 2001  income.
section_title: Study Population and Sample Design
paragraphs: We sought to obtain information about the views of the adult population of  the United States. The study procedures yield a sample of members of the  noninstitutional population of the United States (50 states and the District  of Columbia) who are 18 years or older, speak English, and reside in a  household with a land-based telephone (cellular telephone numbers were  not included in the sample).
Random Digit Dial Equal Probability Selection Methods were followed to  identify households. Survey Sampling International (SSI) of Fairfield,  Connecticut provided the probability sample of telephone numbers. These  were drawn from active telephone blocks of telephone exchanges with  listed numbers and excluded numbers that SSI identified as being business  numbers or not in service (e.g., disconnected). At least eight calls were  made to each telephone number to attempt to identify a respondent.
A member within each household was initially randomly chosen by  selecting the individual whose birthday most recently preceded the date of  the telephone contact. Once the selection of a household member was  made, two attempts were made to complete the interview with that  individual. If, after two contacts, including scheduled appointments, the  selected member could not be reached or refused to complete the survey, a  second adult member of the household was asked to participate. If a  household refused twice, it was not contacted until the final week of data  collection at which time a monetary incentive was offered for completion  of the interview.
Survey respondents are weighted in our analyses so that age, gender, and  regional estimates from our survey will match U.S. data on these  demographic characteristics. The U.S. data come from county-level  estimates from Census 2000 that were projected forward by SCAN/U.S.,  Inc. to July 1, 2002.
section_title: Sources of Error
paragraphs: As with all sample surveys, this survey is subject to both sampling and  nonsampling errors. The effects of sampling errors, due to the selection of  a sample from a larger population, can be expressed as confidence  intervals based on statistical theory. The effects of nonsampling errors,  such as nonresponse and errors in measurement, may be of greater or  lesser significance but cannot be quantified on the basis of the available  data.
Sampling errors arise because we used a sample of individuals to draw  conclusions about the much larger population. The study’s sample of  telephone numbers is based on a probability selection procedure. As a  result, the sample was only one of a large number of samples that might  have been drawn from the total telephone exchanges from throughout the  country. If a different sample had been taken, the results might have been  different. To recognize the possibility that other samples might have  yielded other results, we express our confidence in the precision of our  particular sample’s results as a 95 percent confidence interval. For all the  percentages presented in this report, we are 95 percent confident that  when only sampling errors are considered the results we obtained are  within +/- 5 percentage points or less of what we would have obtained if we  had surveyed the entire study population. In addition to the reported  sampling errors, the practical difficulties of conducting any survey  introduce other types of errors, commonly referred to as nonsampling  errors. For example, questions may be misinterpreted, some types of  people may be more likely to be excluded from the study, errors could be  made in recording the questionnaire responses into the computer-assisted  telephone interview software, and the respondents’ answers may differ  from those who did not respond.
To test the understanding of the questions, we pretested the survey by  conducting 57 interviews. To ensure that responses were correctly  recorded in the computer-assisted telephone interview software, trained  interviewers were used who had been specifically briefed on the study, and  interviewer supervisors regularly monitored, evaluated, and provided  feedback to the interviewing staff who worked from a centralized  telephone facility.
For this survey, the 46 percent response rate is a potential source of  nonsampling error; we do not know if the respondents’ answers are  different from the 54 percent who did not respond. Both GAO and Marist  took steps to maximize the response rate—the questionnaire was carefully  designed, at least eight telephone calls were made at different times of day  on different days of the week to try to contact each telephone number, the  interview period extended over 20 days, respondents were informed that  their responses were anonymous, suspended interviews and refusals were  recontacted at least once, and respondents were provided with a toll-free  number to either call back at a more convenient time or to obtain further  information about the survey.
Because we did not have information on those taxpayers who chose not to  participate in our survey, we could not estimate the impact of the  nonresponse on our results. Our findings will be biased to the extent that  the people at the 54 percent of the telephone numbers that did not yield an  interview have different experiences with paid tax preparers than did the  46 percent of our sample who responded. Knowing that the survey would  concern tax issues could not have created large biases because only about  1.6 percent of the eligible households in the sample (31 individuals) refused  after the interview began (i.e., after they could have known the interview  would address tax issues.) The remaining nonresponding units (about 52  percent of the sample) did not know that the interview would address tax  issues. The 52 percent is comprised of about 18 percent (356) who refused  before the interview could be started, about 14 percent (274) where an  eligible respondent was identified in the household, and about 21 percent  (estimated 418) where no one was contacted at the telephone number but  the household was assumed to be eligible. This estimate of 418  uncontacted, but eligible, households is derived assuming that the  percentage of eligible households among all our 704 uncontacted  households would be the same (59.14 percent) as the percentage of eligible  households among households for which the eligibility status was  determined.
To obtain examples of paid preparer performance, we conducted in-depth  interviews with 18 taxpayers from our nationwide survey of taxpayers. In  addition, we discussed paid preparer performance and received examples  of paid preparer performance from various IRS offices, some paid  preparers, some low-income tax clinics, and IRS’s Taxpayer Advocate  Service. To obtain information on the fees charged by paid preparers for  electronic filing and refund anticipation loans we contacted seven  preparers posing as potential clients and also gathered loan cost schedules  from the Web sites of two lenders. We also reviewed closed case files in IRS  offices, including the Office of Professional Responsibility (OPR), Small  Business/Self-Employed (SB/SE) division, and Criminal Investigation (CI)  division.
A copy of the survey is in appendix II.
section_title: In-depth Interviews with Taxpayers
paragraphs: As part of our nationwide survey of taxpayers, we asked the individuals we  contacted if they would be willing to participate in an in-depth interview  regarding their experiences with paid tax preparers. For those taxpayers  who agreed, we used a structured questionnaire that covered, for example,  how taxpayers found their paid preparers and investigated the credentials  of the preparer, the type of preparer used, why the taxpayer used a paid  preparer, and how extensively the preparer probed the taxpayers’ personal  tax circumstances and asked for documentation. We interviewed 18  taxpayers in-depth.
section_title: Studies Discussing the Extent of Problems Caused by Paid Preparers
paragraphs: To obtain studies discussing the extent of problems caused by paid  preparers, we relied upon studies mentioned in interviews with IRS  officials and through periodical searches. We also used a 1997 Consumer  Reports survey of their readership concerning paid preparers, a report by  the Treasury Inspector General for Tax Administration regarding  potentially unclaimed child tax credits, a Department of Treasury study  regarding earned income tax credits, and a previous GAO report that  estimated the number of taxpayers eligible to itemized deductions who  used the standard deduction instead.
section_title: Objective 2: Describe IRS’s Oversight of Problem Paid Preparers; Management Challenges Facing IRS’s Offices that Provide Oversight; and Efforts to Address Management Challenges
paragraphs: To describe IRS’s efforts to prevent, detect, and take action against  problem paid preparers, we interviewed officials from IRS offices including  OPR, SB/SE, CI, and the Taxpayer Advocate Service (TAS). IRS officials  said these offices interact the most with preparers. We also reviewed  various documents used by these offices to provide paid preparer  oversight.
To describe challenges facing IRS offices that interact with paid preparers,  especially OPR, and efforts to address those challenges, we interviewed  officials from OPR, including its new Director, as well as officials from  other IRS offices discussed above, such as SB/SE and CI. We also used  documents from OPR, including a consulting firm report on the office of  Director of Practice and documents from other IRS offices.
To examine IRS’s efforts to assess and collect penalties against paid  preparers, we interviewed officials from IRS’s SB/SE division, reviewed  collection data, and examined division documents. To determine the  percentage of assessed fines collected and uncollected by SB/SE we relied  upon a SB/SE analysis of collections data extracted from IRS’s  Enforcement Revenue Information System. To assess the reliability of  these data, we reviewed existing documentation related to the data sources  and interviewed officials knowledgeable about the data. We determined  that the data were sufficiently reliable for the purposes of this report.
To obtain information about IRS’s efforts to register and monitor Electronic  Return Originators (ERO), we interviewed officials from SB/SE’s ERO  Monitoring Program and reviewed IRS Publication 1345 covering  requirements for EROs. To determine the number of EROs, monitoring  visits, and sanctions issued, we relied upon IRS’s e-file Provider Monitoring  Report. In addition, we reviewed various other documents including a  recent report by the Treasury Inspector General for Tax Administration.
To describe IRS’s efforts to investigate criminal and fraudulent paid  preparer behavior, we interviewed officials from CI and reviewed case file  information. We used data from the CI Management Information System  and interviewed CI officials to determine statistics on the cases worked. To  assess the reliability of these data, we reviewed existing documentation  related to the data sources and interviewed officials knowledgeable about  the data. We determined that the data were sufficiently reliable for the  purposes of this report.
To examine efforts suggested by IRS’s Taxpayer Advocate Service to  provide additional IRS oversight of paid preparers or provide more  consumer protection, we interviewed officials from the Advocate’s office  about a proposal to license paid preparers. We also reviewed the 2001 and  2002 National Taxpayer Advocate’s reports to Congress where the  Advocate’s proposals are explained and discussed.
To provide examples of actions taken against problem paid preparers by  other federal, state, and local governments, we relied upon interviews and  reports from a variety of sources including paid preparers, professional and  consumer organizations, officials from several states, and some federal  agency representatives. Based on these interviews and reports, we  examined state and local laws that create oversight of certain aspects of  paid preparer behavior. We did not attempt to identify all federal, state, and  local governments or professional organizations that have a paid preparer  or RAL oversight role. Those discussed are only examples of what we  found during our research and there may be others.
The data cited from IRS for the estimated number of individual filers in  2001 that paid someone to prepare their tax returns, the amount paid in  2000 for tax preparation, the number of paid preparers in 1999, and the  number of RALs taken out in 2001 and 2000 are considered background  information. As such, we did not verify these numbers.
We conducted our work from April to October 2003 in accordance with  generally accepted government auditing standards.
section_title: Final Survey Results Weighted to the U.S. Population
subsections: section_title: Survey Results1
paragraphs: “We have a few questions about your experiences last year in completing  your federal income tax return. We are interested in whether or not you  paid someone last year to fill out your 2001 income tax return.” “Did you pay someone to prepare your tax return last year?” __47__ YES (Continue with Question 2)  __51__ NO (Stop) “For the rest of the questions, we’ll refer to this person as the paid preparer. Was the paid preparer who filled out your tax return: A) A tax  preparation service such as H & R Block or Jackson-Hewitt, B) An accountant, CPA or lawyer, C) Someone else, or D) do you not know?”
We are 95 percent confident that the percentage estimates of our survey are within +/- 5 percentage points or less of what we would have  obtained if we had surveyed the entire study population. * Percents do not add to 100 due to rounding. “Next, we ask about some of the practices that paid preparers sometimes follow. For each one, please tell me whether you know if it is  something your paid preparer did do or did not do or whether you do not know.” “First, did your paid preparer give you a copy of your completed tax return,  not give you a copy or do you not know?”  __95__ YES, GAVE COPY  ___1__ NO, DIDN’T GIVE COPY (skip to 4c)  ___4_ DON’T KNOW (skip to 4c) “Did your paid preparer sign your copy of your completed tax return as the preparer, not sign your copy, or do you not know?” “Did your paid preparer see any documents that showed the income you received or any deductions or tax credits that you might have  claimed? That is, did the paid preparer see the documents, not see them, or do you not know?” “For the next question, I want you to think about everything about you that affects the amount of taxes you pay, such as whether or not you  have children at home, earn interest from a bank account, or pay a mortgage. Do you believe that your paid preparer had enough  information about your situation to accurately prepare your income tax return, didn’t have enough information, or don’t you know?” ____5_ NOT AT ALL CONFIDENT  * Percents do not add to 100 due to rounding. “Has the IRS sent you any type of notice saying that any part of your tax return from last year had to be changed, or has the IRS not  contacted you, or do you not know whether you have been contacted?” “Now think about your new 2002 tax return that is due soon. Do you think you will use a paid preparer again or not use a paid preparer for  this new tax return?” __87_ YES, USE A PREPARER AGAIN  ___7_ NO, NOT USE A PREPARER (stop)  ___6_ DON’T KNOW (stop) “The U. S. General Accounting Office is doing research on peoples’ opinions and experiences with their paid preparers. Would it be okay  with you if someone from the General Accounting Office telephoned you in the next month for a research interview?” __45_ YES (NOT REWEIGHTED TO U.S.  __54_ NO (stop) POPULATION)
section_title: Comments from the Internal Revenue Service
section_title: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Acknowledgments
paragraphs: In addition to those named above, Vince Balloon, Larry Dandridge,  Katherine Davis, Michele Fejfar, Evan Gilman, Tre Forlano, Brittni Milam,  Libby Mixon, Cheryl Peterson, and Peter Rumble made key contributions  to this report.
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section_title: Public Affairs