I am open to Robert Flach’s idea of grandfathering unlicensed tax preparers such as himself, who can demonstrate a certain amount of experience and a certain amount of continuing education.
I am not open to the idea of requiring a CPA or an attorney to take the RTRP exam.
I agree completely that it’s wrong for the public to automatically assume that CPA equals “tax expert.” As an enrolled agent, I am as annoyed as anyone over that misconception.
But forcing a CPA or an attorney to take an open-book exam over basic tax law would be insulting to CPAs and attorneys. They have already passed much, much more rigorous tests. They are already held to ethical standards by their state boards, and I believe one of those standards is to not practice in an area in which they don’t have knowledge.
And anyway, what would it prove? The RTRP exam is an open-book test over basic tax law. I understand that people who have passed the RTRP exam say that it’s actually harder than it sounds. Regardless, it’s still a test over basic tax law — it’s not designed to be a “tax expert” test. It’s a basic, entry-level exam for people who haven’t already passed a licensing exam.
More to come in future blog posts.
(UPDATE: Robert Flach has posted a response to this post on his “The Tax Professional” blog.)