Thomas Bridgman, EA, noted some changes that the new Circular 230, effective July 26, 2011, makes to what constitutes “disreputable conduct”, that is, grounds for OPR discipline. These are (with citations to Circular 230):
10.51(a)(16): willful failure to electronically file returns that are required to be so filed
10.51(a)(17): willfully preparing all (or substantially all) or signing as paid preparer a return when the preparer does not possess a valid PTIN
10.51(a)(18) willfully representing a taxpayer before an IRS officer or employee unless authorized to do so by Circular 230
These seem to go to the Registered (or unregistered, as the case may be) Preparers, the latest category of persons subject to Circular 230.
Thanks, Mr Bridgman. Now let’s see how this plays out in practice–hopefully not involving anyone we know!