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CPE EA Renewal Compliance Problem ( I really screwed up this time)

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    CPE EA Renewal Compliance Problem ( I really screwed up this time)

    Hi Fellow Professionals:

    I’m wondering if anyone has experienced this type of issue in real life with EA renewal and CPE compliance problems. I've got 3 options for my problem below and just wondered if anyone could advise me on this. Again, it would be wonderful if you actually experienced this issue first hand or had knowledge of anyone who did.

    MY PROBLEM:
    I’m about to complete the 3rd year of my EA cycle and I realize to my horror that I haven’t complied with the 16 hour per year minimum. (this is my 3rd time renewing, I have no valid excuse for forgetting this rule ) So, my CPE hours look like this :
    2014: 4 hours
    2015: 5 hours
    2016: 5 hours

    So, yes, I screwed up. So, in order to fix this, I figured that these are my options:

    3 CHOICES TO SOLVE MY PROBLEM

    1) The cavalier non worrier option:
    I can study like a madman between now and December 31, to achieve the 72 hours required during 3 year EA period. Maybe the IRS will be satisfied that I’ve completed the 72 hour total for the 3 years and cut me some slack because my record is squeaky clean since I became an EA in 2010. So, maybe I shouldn’t draw attention to myself by submitting the CPE waiver form for my failure to comply with the 16 hour per year minimum? After all, I renewed my license previously and I hadn’t completed 2 hours of ethics per year, but completed 6 hours during the final year to make it up. The IRS renewed my license just the same. Also, it seems the IRS is anxious to give EAs another shot since they value our service and we help to make the IRS work better.

    2) The boy scout safe and scared option:
    Same as Option #1, except that I submit a CPE waiver form for the failure to meet the 16 hour per year requirement for those 2 years. I really don’t have a compelling reason to request the waiver other than I’m a good guy with an otherwise clean record, who made a bonehead mistake.

    3) DEFCON # 3 Mode
    Okay, according to Circular 230 (§ 10.6 — Page 13), there’s a rule that seems to state that I could also renew my EA license by passing all 3 parts of the SEE exam AND by taking 16 hours of CPE by December 31st. If I could do it this way, this might be a little easier than taking the 62 hours catch up CPE hours. Anyway, here’s the section that I’m referencing:
    Circular 230 (§ 10.6 — Page 13) Achieving a passing score on each part of the Special Enrollment Examination administered under this part during the three year period prior to renewal; and (ii) Completing a minimum of 16 hours of qualifying continuing education during the last year of an enrollment cycle.


    Your thoughts on this ? Thanks so much for your time and attention. Happy Holidays

    Best, David

    #2
    I suspect that Option #1 will work, but you should call them and ask about it.

    The telephone number on my last EA certificate is (313) 234-1280.

    Comment


      #3
      Ea con ed record keeping

      Not the first time this has happened to a practitioner, EA, CPA, etc. Won't be the last.

      However, I am bit surprised that the TTB folks have not included a record keeping form as part of their 'worksheet' collection. True, they probably keep track of CE earned using their offerings (which I have not yet availed for myself). Just surprised that they don't have such a document.

      Best wishes to the orignal postor on this thread.

      My recent activity on behalf of preparers with similar issues has found a "tightening of the screws" as it were in several similiar situations. The worst case scenario I suppose is you have to re-take the EA exam at some point.

      Good luck.
      Friends double; family triple. Don't buy an audit for yourself. If someone has to go to jail make sure it is the client. Remember it is only taxes, nothing important.

      Comment

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