The reasoning might be sound in the latest recommendations brought forward by the Taxpayer Advocacy Panel , but huge questions remain over how any of the panel's latest handful of suggestions might actually be executed.

Of course, strictly speaking, that's not the chief concern of the panel, which was established in October 2002 as a way of improving the Internal Revenue Service's response to taxpayer needs. This year, the citizen panel tackled the Section 7216 regulations or tax preparers as well as the future of the agency's Volunteer Income Tax Assistance and Tax Counseling for the Elderly programs.

But the pair of suggestions that I suspect will generate the largest discussion -- and are probably the two that the panel provided the soundest logic behind recommending taking action on -- are also that two that I suspect will face a huge battle before taxpayers ever get a whiff of seeing actual implementation of the changes.

The controversial pair includes a recommendation to license all paid tax preparers, based on both the preparer's level and area of expertise, as well as require a background check; and to make Free File again available to all taxpayers, though the panel hedged its request that if an income limits must be set, the cap should be at adjusted gross incomes of $100,000, instead of the current $50,000.

The more problematic of that second request might be the afterthought the panel added, suggesting that all software companies participating in the Free File Alliance should include a standard list of tax forms and description of their offerings, and that ultimately, the IRS should develop its own direct filing portal for taxpayers to submit tax returns electronically without any charges.

All of those suggestions aren't the most revolutionary of ideas, but there's little doubt that the commercial tax prep giants (many of whom have taken to advertising for help for the 2006 filing season already) and the huge industry built on do-it-yourself tax software -- some of which have major overlaps -- can't be thrilled by either idea.

It'll be interesting to see what stance, if any, is taken on the report. Dated Aug. 18, the report has yet to be posted on the panel's public Web site, http://www.improveirs.org/, though it can be accessed the TaxProf Blog, at http://taxprof.typepad.com/taxprof_blog/files/taxpayer_advocacy_panel.pdf.

The best next hope for any of the recommendations is that they find their way into one of Taxpayer Advocate Nina Olson's two annual reports to Congress, or IRS Commissioner Mark Everson makes mention of them in public comments.

But the fifth of the panel's recommendations suggests that it's a long way before the major one-size-fits-all tax prep players need to worry. Citing concerns about identity theft, loss of jobs to outsourcing and the "performance irregularities and ethics of government contractors," the panel said t hat the IRS should abandon its plans to outsource the collection of some taxpayer debts to private contractors. Not even four months after the panel voiced its concerns, the lucrative contracts have already been awarded and delinquent taxpayer accounts program were handed out with little fanfare earlier this month.

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