Posted: Apr 27, 2005 By: Kruggel, Lawton & Co., LLC CPAs

Subject: Filing Deadline compression

Comment: I think that the calendar year requirement for Sub S and Partnerships, has led to a seasonal compression of work for practitioners that is becoming almost unworkable.

Secondly, accountants working 70-80 hours weeks for the first 16 weeks a year, cannot lead to a mistake-proof system.

I think Congress, and the IRS need to seriously consider the option of allowing flow-through entities to file on a seasonal basis, various due dates for sub s/partership returns based on name, FEIN, etc. would alleviate some of the errors that must occur due to accountant fatigue.

Perhaps the 444 deposit could be paid/refunded with interet, similar to how the 8868, look back rules work for contractors.

I think various years for Sub S/Partnership should be mandated based on some criteria, unless the flow-through entity can show a seasonal/business filing reason for choosing a fiscal year. If everyone has to compy with the new requirements for flow-through, the workload compression would be relieved significantly, and the possible errors that accountants may be making should also be significantly reduced.