§6694, as amended by the Small Business Act, now applies to the universe of paid tax advisers and preparers with respect to all federal tax issues. Any person who receives compensation with respect to a federal tax matter that will or may eventually be reported on a return or claim for refund is potentially a “tax return preparer” and, as such, may be subject to the §6694 preparer penalty. Thus, the applicability of the preparer penalty to a particular practitioner depends on who is treated as a tax return preparer under the new proposed regulations.
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