Tax preparer deadline audit: tests for each register row

What to take away

Test each row for an owner and a backup

A row passes when it names one owner, one backup, and the agency that sets the date. Two names with no source still leave the date open to guesswork. Run the same questions down the whole register, one row at a time, and mark every row that fails.

A thin register is often faster to rebuild than to patch. The five steps below start from a blank sheet and finish before the first return is prepared. Each rebuilt row then goes through the tests in the table that follows, one at a time.

The dates themselves come from the agency that sets them. The audit tests how each row is kept, so the table below needs no dates.

A register that sits in one spreadsheet and one shared calendar can be audited in a morning. A register spread across five inboxes cannot, so merge the copies first and test the rows only after one version remains.

Check reminders, channels, and proof of filing

Reminders at 30, 14, and 3 days before each date give the owner three chances to catch a problem before the date arrives. A single alert on the due date is too late to help anyone.

Each row should also hold the channel and the confirmation the agency returns. Open a few rows from last season and look for the stored confirmation. If it cannot be found quickly, the proof step has a gap, and the owner should attach the confirmation to the row from now on.

The IRS publishes each season's opening date and its e-file shutdown windows, which give the register a verified anchor. Check the current IRS filing season dates instead of copying last year's list, and note that source on the row.

When a due date falls on a weekend or a holiday, the agency pushes it to the next business day, so the register has to hold the published date, not the rule of thumb. Deadline tracking software can hold owners and reminders, but the date still needs checking against the agency's own page.

Find the rows that one person holds

A row held by one trained person is a single point of failure. Extension season punishes practices that keep one trained name per deadline, so the audit looks for those rows before it looks at anything else.

Sort the register by owner and count the hard dates under each name. Where one person carries most of a busy stretch, name a second person and cross-train them on those rows. A backup column only counts when the backup has done the filing once.

Ownership differs by row type. Individual and entity returns sit with the preparer, estimated payments sit with the client with a practice reminder, payroll deposits sit with the payroll lead, and e-file windows sit with the software lead. Write the role on the row, not only the name.

When a date is missed anyway, the practice needs a written missed client deadline procedure. The audit exists to make that procedure rare.

Keep state and provincial rows off the federal date

A federal extension does not move a state or provincial deadline, so each of those rows needs its own date and its own source. Never copy the federal date into a state row as a placeholder.

Name the agency that sets each date, such as the California Franchise Tax Board or the New York State Department of Taxation and Finance, and add that state's own extension form. Confirm the published date before telling a client that April covers everything. The state deadline differences show why.

Practices that also file Canadian returns need a second block. The CRA sets the federal date, and Alberta, Quebec, and Ontario each add their own return dates, payment dates, and filing channels. The provincial tax deadline differences are worth mapping before February.

A practice that files Canadian returns also needs a CRA EFILE number. Registration or renewal carries its own date on the CRA EFILE pages, so give it a row beside the client-facing dates.

Confirm the records behind each filing

A deadline is defensible only if the working papers behind it still exist. Retention rules decide how long engagement letters and source documents stay available, so each filing row should point to the rule that applies.

On the US side, the IRS generally expects income and expense records kept three years after the return is filed, and employment tax records for four years after the tax is due or paid. The CRA record retention period runs six years from the end of the tax year, with Quebec and GST/HST variations.

Audit the storage side against three checks:

Audit payroll rows and the preparer's own date

Payroll deposits slip quietly, so audit them row by row. When a date slips, the penalty arrives weeks later and rarely names the person who missed it. Reading the payroll tax mistakes list before season starts costs less than answering a notice in June.

Every payroll client needs a row with the deposit frequency that applies to them. Monthly and semiweekly depositors do not share dates, and a client whose size changes mid-year can change schedule, so recheck the frequency before each season starts.

For Canadian payroll, the remittance date follows the pay period rather than the month. Group those rows in their own block so a short month does not hide a due date, and give each one the same owner, backup, and source tests as every US row.

The preparer's own date goes in the register too. A PTIN is valid for one calendar year and expires on December 31, so renewal has to be finished before the year turns. The PTIN requirements page states the renewal window that applies and the steps to renew.

Common questions