what to do during tax busy season
4
items to memorialize in a control log to help avoid missed deadlines
Every busy season, there are untimely filed tax returns, and claims can arise from this. A control log is a great way to mitigate the risk of a claim, but have you considered adding these items to your docket system?
Include all tax returns and related forms,
such as estate tax returns, those related to minor children, unfunded trusts, foreign financial accounts, and state filings, even if the client falls below the filing threshold in the current year or if no tax is due.
1
2
Incorporate PPP loan forgiveness applications deadlines, if applicable.
If a client has engaged the firm to assist them in applying for loan forgiveness, add the final date to file the request into the firm’s control log or docket system. If a deadline is missed and proceeds are not forgiven, the client may blame the CPA.
3
Remember to include IRS and state correspondence
with due dates for notices and information document requests. The IRS accumulated more than 11 million pieces of unopened mail after reducing operations due to COVID-19, approximately half of which remained unopened as of October 2, 2020. Obtain powers of attorney so the firm may access the IRS’s e-systems to understand the status of items caught-up in the backlog. Documentation will be critical, including receiving notices from clients timely and retaining copies of certified mail receipts. If correspondence is lost or misplaced by the IRS, and the CPA does not have appropriate documentation, clients may blame their CPA for adverse consequences. Consider including reminder dates in the control log for follow-up with the client or tax agency, if warranted
4
Consider memorializing the following information
in the control log:

  • Original and extended filing due dates for each tax return,
  • Responsible client parties,
  • Information receipt date,
  • Date(s) additional information is requested or questions asked,
  • Date(s) of client response(s) to additional information requested,
  • Completion dates by preparers and reviewers,
  • Approvals by the firm and client, and
  • Assembly, delivery, mailing, filing and acceptance dates.