This serves to inform you of this firm’s policy of disclosure with respect to tax return information in connection with the firm's engagement.

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We shall not knowingly or recklessly disclose the information you furnish us except as provided by law.  We may disclose tax return information to an officer or employee of the Internal Revenue Service.  

 

If the firm provides software to you that is used in connection with the preparation or filing of your tax return, the tax return preparer may use your tax return information to update your software for the purpose of addressing changes in IRS forms, e-file specifications and administrative, regulatory and legislative guidance, or to test and ensure the software's technical capabilities without the taxpayer's consent. In addition, an officer, employee, or member of the firm may use the tax return information, or disclose the tax return information to another officer, employee, or member of the same firm, for the purpose of performing services that assist in the preparation of, or assist in providing auxiliary services in connection with the preparation of, the taxpayer's tax return, except with respect to such individuals who are located outside the United States or any territory or possession of the United States unless you give consent to such use or disclosure.

 

In general, an officer, employee, or member of the firm may disclose tax return information to another tax return preparer (who is not an officer, employee, or member of the firm located in the United States (including any territory or possession of the United States) for the purpose of preparing or assisting in preparing a tax return, or obtaining or providing auxiliary services in connection with the preparation of any tax return, so long as the services provided are not substantive determinations or advice affecting the tax liability reported by taxpayers. A substantive determination involves an analysis, interpretation, or application of the law. The authorized disclosures permitted include one tax return preparer disclosing tax return information to another tax return preparer for the purpose of having the second tax return preparer transfer that information to, and compute the tax liability on, your tax return by means of electronic, mechanical, or other form of tax return processing service. The authorized disclosures permitted also include disclosures by a tax return preparer to an Authorized IRS e-file Provider for the purpose of electronically filing the return with the IRS. Authorized disclosures also include disclosures to a second tax return preparer for the purpose of making information concerning the return available to the taxpayer. This would include, for example, whether the return has been accepted or rejected by the IRS, or the status of your refund. The firm may not disclose tax return information to another tax return preparer for the purpose of the second tax return preparer providing substantive determinations without first receiving the taxpayer's consent. The firm may disclose tax return information to a person under contract with the tax return preparer in connection with the programming, maintenance, repair, testing, or procurement of equipment or software used for purposes of tax return preparation only to the extent necessary for the person to provide the contracted services, and only if the tax return preparer ensures that all individuals who are to receive disclosures of tax return information receive a written notice that informs them of the applicability of §§6713 and 7216 to them and describes the requirements and penalties of such sections.

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In preparing a tax return of a second taxpayer, the firm may use, and may disclose to the second taxpayer in the form in which it appears on the return, any tax return information that the tax return preparer obtained from you if the second taxpayer is related to you, and your tax interest in the information is not adverse to the second taxpayer's tax interest in the information. However, you may expressly prohibit such disclosure or use. For these purposes, a taxpayer is related to another taxpayer if they have any one of the following relationships: Husband and wife, child and parent, grandchild and grandparent, partner and partnership, trust or estate and beneficiary.

 

The disclosure limitations do not apply to  the order of any court of record, federal, state, or local; a subpoena issued by a grand jury, federal or state; a subpoena issued by the United States Congress; an administrative order, demand, summons or subpoena that is issued in the performance of its duties by any federal agency, or a state agency, body, or commission charged under the laws of the state or a political subdivision of the state with the licensing, registration, or regulation of tax return preparers; a written request from a professional association ethics committee or board investigating the ethical conduct of the tax return preparer; or a written request from the Public Company Accounting Oversight Board in connection with an inspection under §104 of the Sarbanes-Oxley Act of 2002, or an investigation under §105 of such Act, for use in accordance with such Act. The firm may disclose tax return information to an attorney for purposes of securing legal advice; to an employee of the Treasury Department for use in connection with any investigation of the tax return preparer (including investigations relating to the tax return preparer in its capacity as a practitioner) conducted by the IRS or the Treasury Department; or to any officer of a court for use in connection with proceedings involving the tax return preparer (including proceedings involving the tax return preparer in its capacity as a practitioner), or the return preparer's client, before the court or before any grand jury that may be convened by the court.

 

The firm may use your tax return information, or disclose the information to another officer, employee or member of the firm, consistent with applicable legal and ethical responsibilities, who may use the tax return information for the purpose of providing other legal or accounting services to you. As an example, an accountant who prepares a tax return for you may use the tax return information, or disclose it to another officer, employee or member of the firm, for use in connection with the preparation of books and records, working papers, or accounting statements or reports for you. In the normal course of rendering the accounting services to you, the accountant may make the tax return information available to third parties, including stockholders, management, suppliers, or lenders, consistent with the applicable legal and ethical responsibilities, unless you direct otherwise.

 

A tax return preparer's accounting firm does not include any related or affiliated firms. For example, if accounting firm A is affiliated with accounting firm B, officers, employees, and members of accounting firm A must receive a taxpayer's consent before disclosing the taxpayer's tax return information to an officer, employee, or member of accounting firm B.

The firm may, consistent with the applicable legal and ethical responsibilities, take your tax return information into account, and may act upon it, in the course of performing accounting services for another client, or disclose the information to another officer, employee or member of the firm to enable that other officer, employee or member to take the information into account, and act upon it, in the course of performing accounting services for another client. This is permissible when the information is, or may be, relevant to the subject matter of the accounting services for the other client, and consideration of the information by those performing the services is necessary for the proper performance of the services. In no event, however, may the tax return information be disclosed to a person who is not an officer, employee or member of the accounting firm, unless the disclosure is exempt from the disclosure provisions.

 

If, after furnishing tax return information to the firm, the [trust or estate] becomes incompetent, insolvent, or bankrupt, or its assets are placed in conservatorship or receivership, the firm may disclose the information to the duly appointed fiduciary of such estate, or to the duly authorized agent of such fiduciary.

 

The uses and disclosures with respect to software preparation, other tax return preparers within the firm, and tax return preparers located outside the United States, as well as the disclosures to other tax return preparers within the United States and the disclosures to programming and maintenance contractors permitted above apply to the disclosure of any tax return information in the preparation of, or in connection with the preparation of, any tax return under the law of any state or political subdivision thereof, of the District of Columbia, of any territory or possession of the United States, or of a country other than the United States. The nondisclosure and non-use provisions do not apply to the use by the firm of any tax return information in the preparation of, or in connection with the preparation of, any tax return of yours under the law of any state or political subdivision thereof, of the District of Columbia, of any territory or possession of the United States, or of a country other than the United States. They also do not apply to the disclosure or use by any tax return preparer of any tax return information in the audit of, or in connection with the audit of, any tax return of yours under the law of any state or political subdivision thereof, the District of Columbia, or any territory or possession of the United States.

 

The firm may use and disclose tax return information that you provide to us to pay for tax preparation services to the extent necessary to process or collect the payment. For example, if you give us a credit card to pay for tax preparation services, the firm may disclose your name, credit card number, credit card expiration date, and amount due for tax preparation services to the credit card company, as necessary, to process the payment. Any tax return information that you did not give us for the purpose of making payment for tax preparation services may not be used or disclosed by the firm without your prior written consent, unless otherwise permitted under another provision.

 

The firm may retain your tax return information, including copies of tax returns, in paper or electronic format, prepared on the basis of the tax return information, and may use the information in connection with the preparation of another of your tax returns or in connection with an examination by the Internal Revenue Service of any tax return or subsequent tax litigation relating to the tax return. The firm may compile and maintain a separate list containing solely the names, addresses, email addresses, and phone numbers of taxpayers whose tax returns the firm has prepared or processed. This list may be used by the compiler solely to contact the taxpayers on the list for the purpose of providing tax information (and general business or economic information or analysis for educational purposes), or soliciting additional tax return preparation services. The list may not be used to solicit any service or product other than tax return preparation services. The compiler of the list may not transfer the taxpayer list, or any part thereof, to any other person unless the transfer takes place in conjunction with the sale or other disposition of the compiler's tax return preparation business.

 

Due diligence conducted prior to a proposed sale of a compiler's tax return preparation business is in conjunction with the sale or other disposition of a compiler's tax return preparation business, and will not constitute a transfer of the list if conducted pursuant to a written agreement that requires confidentiality of the tax return information disclosed and expressly prohibits the further use or disclosure of the tax return information for any purpose other than that related to the purchase of the tax return preparation business. The tax return information submitted for the purpose of due diligence as authorized in this paragraph is a disclosure of tax return information subject to the provisions of this section.

 

A person who acquires a taxpayer list, or a part thereof, in conjunction with a sale or other disposition of a tax return preparation business is subject to the provisions of this paragraph with respect to the list. The term ‘list’ includes any record or system whereby the names and addresses of taxpayers are retained.

 

The firm may use, for the limited purpose specified, tax return information to produce a statistical compilation of data. The purpose and use of the statistical compilation must relate directly to the internal management or support of the firm's tax return preparation business, or to bona fide research or public policy discussions concerning state or federal taxation or requiring data acquired during the tax return preparation process. The firm will not disclose the compilation, or any part thereof, to any other person unless disclosure of the statistical compilation is anonymous as to taxpayer identity, does not disclose cells containing data from fewer than ten tax returns, and is in direct support of the firm's tax return preparation business or of bona fide research or public policy discussions concerning state or federal taxation or requiring data acquired during the tax return preparation process. A statistical compilation is anonymous as to taxpayer identity if it is in a form which cannot be associated with, or otherwise identify, directly or indirectly, a particular taxpayer. For these purposes, marketing and advertising is in direct support of the tax return preparer's tax return preparation business provided the marketing and advertising is not false, misleading, or unduly influential. This does not authorize the use or disclosure in marketing or advertising of any statistical compilations, or part thereof, that identify dollar amounts of refunds, credits, or deductions associated with tax returns, or percentages relating thereto, whether or not the data are statistical, averaged, aggregated, or anonymous. Disclosures made in support of fundraising activities conducted by Volunteer Return Preparation programs and other 501(c) organizations in direct support of their tax return preparation businesses are not marketing and advertising under this paragraph. The firm may disclose the compilation in order to comply with financial accounting or regulatory reporting requirements whether or not the statistical compilation is anonymous as to taxpayer identity or discloses cells containing data from fewer than ten tax returns.

 

The tax return preparer may not sell or exchange for value a statistical compilation of data, in whole or in part, except in conjunction with the transfer of assets made pursuant to the sale or other disposition of the tax return preparer's tax return preparation business. The provisions regarding the transfer of a taxpayer list also apply to the transfer of any statistical compilations of data. A person who acquires a statistical compilation, or a part thereof, in conjunction with a sale or other disposition of the firm’s tax return preparation business, is subject to these limitations with respect to the compilation.

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The firm may disclose your tax return information for the purpose of a quality or peer review to the extent necessary to accomplish the review. A quality or peer review is a review that is undertaken to evaluate, monitor, and improve the quality and accuracy of a tax return preparer's tax preparation, accounting, or auditing services. A quality or peer review may be conducted only by attorneys, certified public accountants, enrolled agents, and enrolled actuaries who are eligible to practice before the Internal Revenue Service. Tax return information may also be disclosed to persons who provide administrative or support services to an individual who is conducting a quality or peer review, but only to the extent necessary for the reviewer to conduct the review. Tax return information gathered in conducting a review may be used only for purposes of a review. No tax return information identifying a taxpayer will be disclosed in any evaluative reports or recommendations that may be accessible to any person other than the reviewer or the tax return preparer being reviewed. The tax return preparer being reviewed will maintain a record of the review, including the information reviewed and the identity of the persons conducting the review. After completion of the review, no documents containing information that may identify any taxpayer by name or identification number may be retained by a reviewer or by the reviewer's administrative or support personnel.

 

These limitations do not apply to any disclosure necessary to accomplish a conflict review. A conflict review is a review undertaken to comply with requirements established by any federal, state, or local law, agency, board or commission, or by a professional association ethics committee or board, to either identify, evaluate, and monitor actual or potential legal and ethical conflicts of interest that may arise when a tax return preparer is employed or acquired by another tax return preparer, or to identify, evaluate, and monitor actual or potential legal and ethical conflicts of interest that may arise when a tax return preparer is considering engaging a new client. Tax return information gathered in conducting a conflict review may be used only for purposes of a conflict review. No tax return information identifying a taxpayer may be disclosed in any evaluative reports or recommendations that may be accessible to any person other than those responsible for identifying, evaluating, and monitoring legal and ethical conflicts of interest. No tax return information identifying a taxpayer may be disclosed outside of the United States or a territory or possession of the United States unless the disclosing and receiving tax return preparers have procedures in place that are consistent with good business practices and designed to maintain the confidentiality of the disclosed return information. 

 

The firm is not prohibited from the disclosure of any tax return information to the proper federal, state, or local official in order, and to the extent necessary, to inform the official of activities that may constitute, or may have constituted, a violation of any criminal law or to assist the official in investigating or prosecuting a violation of criminal law. A disclosure made in the bona fide but mistaken belief that the activities constituted a violation of criminal law is not subject to the nondisclosure and non-use rules. 

 

In the event of incapacity or death of the tax return preparer, disclosure of tax return information may be made for the purpose of assisting the tax return preparer or his legal representative (or the representative of a deceased tax return preparer's estate) in operating the tax return preparer’s business. 

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We trust this policy is informative, and you may contact us with any questions that you may have.

 

Sincerely,

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Michelle Graham's Tax Services