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Further, section 448(d)(2) requires only that the services
be in the “field of accounting” and is not limited to public
accounting. Historically, tax return preparation and bookkeeping
services are regarded as within the field of accounting.
Accounting has been defined as:
the process of recording transactions in the
financial records of a business and
periodically extracting, sorting, and
summarizing the recorded transactions to
produce a set of financial records. * * *
[Blacks’s Law Dictionary 21 (8th ed. 2004).]
Tax return preparation, which requires extracting
information relating to financial transactions, analyzing that
information, and then summarizing and reporting that information
on a tax return, fits within the above general definition of
accounting.
Also, as discussed above, section 1.448-1T(e)(5)(vii),
Example 1(i), Temporary Income Tax Regs., supra, indicates that,
for purposes of section 448(d)(2), tax return preparation
services are to be treated as accounting services.
We note that under Nevada statutory law “public accounting”
includes “the preparation of tax returns”. Nev. Rev. Stat. Ann.
sec. 628.023 (Lexis Nexis 2004).
We note further that a defining characteristic of our
Federal income tax system is the reporting of financial
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