The NSA recommended that all tax preparers, including volunteers and those who prepare returns in conjunction with other services, be required to register and obtain a Preparer Tax Identification Number. The association noted the Treasury Inspector General for Tax Administration has found that least 31 percent of tax returns prepared by volunteers were incorrect. The IRS proposals do not cover these individuals. Requiring them to get PTINs would enable the IRS to identify common mistakes and which individuals are making them and enable steps to be taken to educate those volunteers, according to the statement.

Those providing "free" preparation in conjunction with unrelated services such as
automobile purchases, appliance sales promotions, payday loans and refund anticipation loans should also be required to obtain a PTIN, the group said.  And it wants non-U.S.-based tax preparers to be allowed to obtain and use identification numbers.

The NSA asked for IRS guidance on defining whether a preparer has assisted in the preparation of “substantially all” of a tax return and must have a PTIN under the new regulations. Under the proposals, CPAs, tax attorney and Enrolled Agents are exempt from continuing education and testing requirements. But they would be required to get PTINs. One area in which many seem to have questions is how far the requirements extend to those involved in the return process at firms.

Among other recommendations was the NSA's position that any deadline for required registration for PTINs be extended until a competency test is available and also making the effective dates contingent on the implementation of a public awareness campaign by the IRS.