This statement sets forth the applicable standards for members when signing the preparer’s declaration on a tax return if one or more questions on the return have not been answered. The term questions includes requests for information on the return, in the instructions, or in the regulations, whether or not stated in the form of a question.
A member should make a reasonable effort to obtain from the taxpayer the information necessary to provide appropriate answers to all questions on a tax return before signing as preparer.
It is recognized that the questions on tax returns are not of uniform importance, and often they are not applicable to the particular taxpayer. Nevertheless, there are at least three reasons why a member should be satisfied that a reasonable effort has been made to obtain information to provide appropriate answers to the questions on the return that are applicable to a taxpayer:
A question may be of importance in determining taxable income or loss, or the tax liability shown on the return, in which circumstance an omission may detract from the quality of the return.
A request for information may require a disclosure necessary for a complete return or to avoid penalties.
A member often must sign a preparer's declaration stating that the return is true, correct, and complete.
Reasonable grounds may exist for omitting an answer to a question applicable to a taxpayer. For example, reasonable grounds may include the following:
The information is not readily available and the answer is not significant in terms of taxable income or loss, or the tax liability shown on the return.
Genuine uncertainty exists regarding the meaning of the question in relation to the particular return.
The answer to the question is voluminous; in such cases, a statement should be made on the return that the data will be supplied upon examination.
A member should not omit an answer merely because it might prove disadvantageous to a taxpayer.
A member should consider whether the omission of an answer to a question may cause the return to be deemed incomplete or result in penalties.
If reasonable grounds exist for omission of an answer to an applicable question, a taxpayer is not required to provide on the return an explanation of the reason for the omission.
The Statements on Standards for Tax Services (SSTSs) are enforceable tax practice standards for members of the AICPA. Additional guidance is also found in the corresponding interpretations and frequently asked questions (FAQs). Access to the complete set of SSTSs and guidance are available in the AICPA’s Statements on Standards for Tax Services Library.