Sabina Loving V. Internal Revenue Service Case Study

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Introduction
The case of Sabina Loving, et al. v. Internal Revenue Service, et al. was originally filed on March 13, 2012 by three independent tax preparers. Sabina Loving of Chicago, IL; John Gambino of Hoboken, NJ; and Elmer Kilian of Eagle, WI. alleged that the IRS had over-stepped its authority when they required tax preparers be licensed. According to Kimberly Stanley J.D., LL.M., “about 40 percent of paid return preparers are attorneys, CPAs, or enrolled agents, the remaining 60 percent have no professional credential or license at all” (Stanley, “Loving v. IRS and Tax Return Preparer Regulations”). Many of these preparers have been in business for decades and had a legitimate dispute against the certification requirements. In 2012, the …show more content…

Commissioner
The IRS sensibly decided against a Supreme Court review of the decision; however, in June 2014, they announced that they would introduce a voluntary program to regulate independent tax return preparers. In lieu of instituting a mandatory program the IRS created a voluntary program, called the Annual Filing Season Program, which would provide a preparer with a record of completion each year upon showing that they have registered with the IRS and completed the required continuing education; furthermore, the record of completion is effective for one calendar year.
Moreover, to receive a record of completion from the IRS, the independent preparer must agree to accept the duties and restrictions relating to practice before the IRS in subpart B and section 10.51 of Treasury Department Circular No. 230. Rev. Proc. 2014-42 § 4.05(4). The voluntary program does not bind return preparers to all of Circular 230. Subpart B of Circular 230 describes noncontroversial ethical duties and responsibilities applicable to anyone who represents a taxpayer before the IRS, such as the duty to provide information promptly when requested, the duty not to charge an unconscionable fee, and rules regarding conflicts of interests and solicitation of

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