🚨 Due Diligence Reality Check: Form 8867 Is Not Your Protection
Most tax pros think due diligence starts and ends with Form 8867. But here’s the hard truth: 8867 is just the starting point, not your shield. When preparers get hit with IRS penalties, it’s rarely because they forgot to attach a form. It’s because they couldn’t prove the client actually qualified. The IRS doesn’t hand you a perfect script of every question to ask. Beyond the basic worksheets, you are responsible for building the proof. ✅ What Due Diligence REALLY Requires Your job is to create a file that shows: - Qualifying questions based on tax law - Documented answers in the client’s file - Follow-up questions based on their responses and documents - Notes that show you caught issues, addressed inconsistencies, and resolved them ⚠️ There Is No “One-Size-Fits-All” Due Diligence File Every client situation is different. Your documentation should clearly show how and why the client qualifies for: - the credit(s) - the filing status - the dependent(s) - any claim that affects the refund What gets most tax pros fined isn’t always fraud. It’s thin documentation: - No written questions - No follow-up notes - Vague “yes/no” answers with no details - No explanation of mismatched info 🧾 Your Due Diligence File Should Tell a Story A clean file should read like this: “Here’s what the client said. Here’s what they provided. Here’s what didn’t add up. Here’s what I asked. Here’s what fixed it. Here’s why they qualify.” So if the IRS reviews the return, they can follow the logic without you in the room. 🛡️ Due Diligence Isn’t Busywork It’s your professional shield. If you haven’t reviewed how you document client qualification lately, do it now. Because when due diligence matters most… it’s already too late to recreate it.