Fees apply to individuals required to take the exams in order to participate in the preparer tax identification number (PTIN), acceptance agent and authorized e-file provider programs. Testing is not required for CPAs, Enrolled Agents and tax attorneys.

"As a threshold matter, we believe it is unnecessary to extend this proposal to the population of Supervised Employees," Thompson testified. She noted these employees cannot sign returns as paid preparers and must be supervised by a CPA.

Thompson noted the IRS had requested comments on whether CPAs should be fingerprinted as part of a suitability check for receive PTINS. Because CPAs are regulated by state agencies, this would be redundant because of the suitability checks by those bodies. She testified that the IRS should letting CPA firms engage a consumer reporting agency regulated by the Federal Trade Commission to perform background checks on supervised employees.

The AICPA is also concerned about the possibility the IRS will stop issuing provisional PTINs as early as April 9. Thompson said discontinuing PTINs would result in "benching" of interns and other supervised employees that are newly hired or temporary while PTIN applications are processed.