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EFIN Suitability Check

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For quick background information, I became interested in tax after needing to clean up a few years of business taxes from a prior (not tax-related) business in years 2013-2015.  I was young, built a business that became successful quickly, and a few errors and habits compounded.  With the help of my accountant I voluntarily prepared amended S-corp and personal returns for mentioned years and paid a significant amount of additional taxes, about $40k.  The IRS assessed a few penalties on the amended 1120s, I believe one was an accuracy related penalty.  I had some unfiled (but not unpaid) 940/941 returns for my s-corp that I cleaned up at the same time.

I sold that business, but the experience sparked an interest in tax.  Unfortunate that it took sloppy mistakes to realize, I know.  I've just finished a bachelors in accounting and am currently studying for the EA exam. 

Based on what I've read in the IRM regarding the enrolled agent suitability test, I should be fine because all returns are filed and paid.  However, I'm curious about the EFIN suitability test in the event I should ever apply.  Especially concerning because denial on an EFIN application would preclude my hiring at another firm.  Publication 3112, page 8, lists several reasons an application may be denied.  Line 2 on that list is "Failure to file accurate federal, state, or local returns".  I am unable to find any other specific sources regarding the EFIN suitability check elsewhere, I've checked several IRB and IRM resources, but none are as specific as the EA suitability checks detailed in the IRM.

Does anyone have more knowledge about this?  I'm concerned that being assessed an accuracy related penalty relating to my voluntary amended returns, along with several untimely filed (but timely paid) 940/941 returns, could meet the "failure to accurately file federal" return threshold listed in Pub. 3112.

Of course, I could always just apply for enrollment as an EA and not apply for an EFIN.  I would prefer to be an employee for several years for the experience, anyway.  However, I'm curious if I'll encounter trouble if I decide to apply for an EFIN.  Probably impossible to know without applying, but the consequences of being denied (inability for a EFIN holder to knowingly hire an EFIN reject) would be terrible after the work of learning from my mistakes, earning a degree, and passing the SEE to become an EA.



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  • 2 weeks later...

I may be mistaken and didn't research for you, but I think the rule and question asked is if you are now presently current on all returns and payments.  I can't answer about questions related to becoming an EA and it's been a long time since I initially applied for my EFIN so YMMV.  The only way to know for sure is to apply and wait for an answer from the IRS.  It's too late for this coming season anyway, so your best bet is to try to find employment with a firm to expand your knowledge and proficiency. 

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