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I have become a big fan of direct pay, after several cases of "missed " postings or "un-identified " deposits. I am not a fan procrastinting payment. And, I also agree with postponing filing awaiting e-file. E-file more positive than "human" . YMM

I am recommending payments NOW (whether via coupon-and-check, or Direct Pay), and e-file later.

I took a different approach. I am not including it in my engagement letter. I sent the BOI instructions to each of my affected clients and told them in the email that I could not prepare it and I was letting them know about their requirement as a courtesy. Not being argumentative, just asking. By putting it in your engagement letter, are you in a backhanded way telling your clients this is a tax issue? I did the above because I don't feel it is a tax issue and it is not my responsibility to even notify them of their requirement to comply. In the same way I don't tell my clients it is their responsibility to file their annual SOS report or their county property tax returns. Tom Longview, TX

I'm working on a case where filing past year(s) by mail is required. This is due to a missing EIN for the firm on form 8919. yes, everything under the sun was tried to get the EIN so we ended up with the word "UNKNOWN" which prevents the return from efiling. I've told the client to wait until we know the IRS has received the return(s) and then use the direct pay to pay the balance due. Would it be better to have him pay what is due now for the remaining years? By this discussion, it sounds like a better idea to do so.

But they do have to do at least enough to justify their budget! NY, trying to ding me (years ago) for submitting junk data to a test only forms person (via mail) for approval to print the form. The data was unusable, with invalid EIN and SSN, but they still sent me a bill - and I did not send to the normal forms adress. Tax agencies who change just text on their form to cause new approval processes. Tax agencies who cannot use simple programming commands like trim, remove, etc, and reject good data.