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TAX

The most recent Section 4.1.7. The member should consider if
the taxpayer’s conduct may be fraudulent or
criminal in nature. If so, the member should
significant updates to advise the taxpayer to retain legal counsel and
refrain from further representation.
the SSTSs were made Section 4.1.8. Upon completion of the exami-
nation by the taxing authority, the member
should review any documents or computations
Jan. 1, 2010. detailing the results of the examination for
correctness and discuss with the taxpayer the
consequences of agreeing to these conclusions.

The SRTPs, predecessors to the SSTSs, were
drafted at a time when tax practices primar-
ily only prepared tax returns. Since then, tax
However, members should also remember that use practices have expanded to provide a wide variety
of a tool does not absolve the member of profes- of services including tax representation. The task
sional obligations under AICPA or other appli- force believed the continuing growth in the num-
cable ethical standards. Therefore, members should ber of CPA firms providing tax representation
consider implementing a general technical review services obligated the development of a standard.
process to ensure work product is accurate. In the course of developing the standard, both
the task force and others raised the question of
SSTS 4, Standards for Members Providing Tax whether a separate standard was necessary, given
Representation Services the breadth of guidance provided by Circular
New standards: 230. Upon discussion of the issue, the task force
Section 4.1.3. The member, and any individuals agreed that Circular 230 does provide significant
working with or for the member, should have or guidance to anyone involved in the representation
take steps to obtain technical competence in the of a taxpayer before a taxing authority. However,
subject matter involved. This includes compe- that guidance applies only to the representa-
tence in the technical tax area involved as well tion of federal tax clients. Task force members
as the tax practice and procedures of the taxing therefore felt it important to develop one overall
authority. For this purpose, competence follows set of standards that would apply to all members
the definition established in Section 10.35 of providing tax services, regardless of tax jurisdic-
[Treasury] Circular 230 [Regulations Governing tion. SSTS 4 is not intended to override other
Practice Before the Internal Revenue Service (31 regulatory standards but rather to supplement
C.F.R. Part 10)]. existing standards and serve as basic standards
where a lower or no standard otherwise exists.
Section 4.1.4. The member should take ap- SSTS 4 does generally follow familiar
propriate steps to ensure compliance with all concepts for experienced tax practitioners. First,
relevant professional and regulatory obligations members can represent taxpayers in an issue they
when representing a taxpayer. do not have direct experience with, but they are
expected to take steps to obtain technical compe-
Section 4.1.5. The member should act with in- tence as part of that representation engagement.
tegrity and professionalism in all dealings with Second, members are expected to comply with all
the taxing authority. This includes not unduly other relevant professional and regulatory obliga-
delaying or impeding the taxing authority. tions in providing representation services, such as
Circular 230 and the AICPA Code of Professional
Section 4.1.6. Information requested by the Conduct (the AICPA Code). Third, members are
taxing authority should, with taxpayer approval, expected to maintain integrity and professional-
be provided by the member on a timely basis ism in dealing with tax authority representatives.
unless there is a good-faith belief that the Fourth, members are expected to, with taxpayer
information is privileged. approval, respond timely to tax authority requests

34 | Journal of Accountancy December 2022