Tax Services Quality Control  ASCPA Letter of Response:August 1, 2006 Mr. Edward S. Karl, CPA Director, AICPA Tax Division 1455 Pennsylvania Avenue, NW Washington, DC 20004-1081 Dear Mr. Karl: Re: File SSTS-9 On behalf of the Arkansas Society of Certified Public Accountants Board of Directors and the Taxation Committee of the Arkansas Society, please accept the following comments regarding the Proposed Statement on Standards for Tax Services. Though your introduction states that “some members have expressed concern over a lack of quality control standard”, we know of no membership survey whose results would indicate that a majority of AICPA members in tax practice would agree. Ultimately, we feel that this is neither the time nor the manner in which additional compliance burdens should be placed on our members. Quality control measures were instituted in the accounting and auditing areas because of an outcry from financial institutions, governmental agencies, and other users of the financial statements who were in need of additional assurance following some blatant and capricious violations by our members of standards already in place. We agree that the actions taken in that area were called for, were beneficial, and probably fended off an intrusion of the SEC and other agencies into our profession; but, with regards to tax practice, from where is such an outcry coming? It is our belief that the standards in place by both the AICPA and the IRS are adequate to assure quality work by our members. IRS states that there are approximately 1.2 million tax return preparers in the United States and that about half of those are CPAs, attorneys, and registered agents. For every professional preparer who is discouraged by additional oversight and cost burdens, there is a non-professional preparer ready and willing to handle his customers. The non-professional only has to comply with IRS regulations. Would such a movement to non-professional preparers improve the quality of work performed? Over the last several years, our profession has had difficulty in attracting young people. Increased costs and compliance requirements will only exacerbate the problem. Our older members who maintain tax practices, many of whom are nearing retirement, really have no need of their CPA certificate or membership in order to retain their clientele due to past relationships and well deserved positive reputation. In fact, several respondents to our inquiries regarding the proposed standard simply stated that if it is instituted, they will relinquish their certificates and/or memberships in the AICPA. We would be remiss in not expressing our appreciation of the Institute’s efforts to improve the quality of work performed by our members; however, by its wording, this standard implies the establishment of another level of peer review. We, the members, do not support such a measure and feel that the Institute has gone beyond both prudence and practicality in considering such an action. Respectfully, Jerry W. Burchfield, CPA, Chairman ASCPA Taxation Committee
|