Frank Sands, president of the National Conference of CPA Practitioners, shares the major issues that tax pros should be paying attention to in the run up to April 15, as well as expectations around IRS responsiveness, and the latest small-business trends.
Transcription:
Transcripts are generated using a combination of speech recognition software and human transcribers, and may contain errors. Please check the corresponding audio for the authoritative record.
Daniel Hood (00:02):
Welcome to On The Air with the Accounting Today I'm editor in Chief Dan Hood. Tax season is fast approaching and this year, like every year brings its own unique set of problems and worries. Here to talk about what's coming up and what tax professionals should be preparing for is Frank Sands. He's president of the National Conference of CPA Practitioners as well as managing partner with his own firm, Sans Gilland in Texas. Frank, thank you so much for joining us.
Frank Sands (00:22):
Thank you for having me, Dan. Appreciate the opportunity.
Daniel Hood (00:25):
Yeah, you and Nick Pap have your fingers on the pulse of all these issues through your membership, but also through your many, many ties and insights into what's going on in Washington. So we're always happy to have you guys here to talk about what's going on. I want to start by asking how apprehensive are you about the upcoming tax season? Do you think it's going to be better or worse than last season?
Frank Sands (00:47):
Well, there's a couple of ways. It'll be better and more than a couple that I am expecting it to be a little bit worse.
Daniel Hood (00:56):
Okay.
Frank Sands (00:59):
I think the Covid apprehension has declined, so I think that will make it better with our clients. I also think that there will be, because of the inflation situation, pressures on folks needing money, I think those that expect to get a refund may bring their taxes in earlier to get 'em done. Of course, we always like that because it gives us a heads up on it and ability to get it done quickly. There are few changes in the tax forms which are inconsequential and there's no major tax laws, knock on wood.
Daniel Hood (01:38):
Yeah, exactly. They
Frank Sands (01:39):
Still got a few weeks left, so we'll see. But as far as what's going to make it more challenging, I think BOI issues, the beneficial ownership issues will come to play because people will come in and ask for them, and these are complicated issues. The IRS has issued notices, which at times are erroneous, and the reason I say that is because it's primarily due to a couple of things, processing delays on payments, processing delays on previous communications sent to them that just haven't been input into their systems, and it creates a situation where they send out letters where maybe they shouldn't have or letters that have incorrect data on them. And of course this always causes a problem. One of the things that happens is many of our clients will wait until their tax appointment to show us these letters,
(02:51):
And that isn't helpful at times because as you are probably aware, there are deadlines involved in these things. There is a new EFI requirement for W twos and 10 90 nines, which we haven't had before, and that is the, if you've got W twos and 10 90 nines that total more than 10 in number, you got efi, which means a lot of the smaller clients are going to be forced to eile these things when they haven't in the past. Any change causes a little unsettling with the client. Biggest concern is the continuing resolution, which is set to expire in February. If the IRS shuts down, you can imagine what kind of problems that's going to create. I mean, the backlogs will grow, taxpayer's assistance won't happen, refund processing, correspondence, payment processing, the whole thing, and that when that happens and then they crank it back up again like they did recently, it leads to more erroneous notices coming out and then the communication back and forth, it's just a real problem. So I hope that doesn't happen.
Daniel Hood (04:12):
Yeah, fingers crossed we don't get a shut down in early January. They post by, that was the thing when they said, oh, we've solved it. We've solved it. Really, they just kicked the can down the road closer to a nightmare period of Right. If it's because usually tax season starts that third week of January, January 20th, something similar between there and the very beginning of February. So that's not going to give people anywhere near enough time to be prepared for a shutdown of the IRS if it should happen, which fingers crossed, knock on wood, we'll hope it doesn't, but let's hope that that doesn't happen, assuming it doesn't. What are some of the big, as I say, NIC Pap pays attention to a lot of the legislation and the regulation coming out of the IRS and helps its members Understand all that. What are the big regulatory and legislative related issues that you're warning your members to be ready for the tax season apart from the terrible possibility of a shutdown?
Frank Sands (05:05):
Well, there's three items that we've been dealing with on a fairly regular basis in anticipation of problems with it, and that is the ERC, the employer retention credit. Of the 10 99 K reporting changes and the beneficial ownership information reporting, the ERC gives us pause. This credit is the credit back on taxes paid due to employment, and you have to amend nine 40 ones to get these credits back and there's some pretty good money involved. I mean, it can be a pretty good sum of money. The current guidance from the IRS and requirements from the IRS is if you get these credits paid to you, then you got to go back and amend the tax return in the year in which that related payroll was deducted, and then the deduction amount has to be reduced by the amount of credit received.
(06:16):
We were communicating with the IRS and with some of our contacts down in Washington along with the A-I-C-P-A, trying to get them to say, Hey, just recognize it as taxable income in the year you get it, and don't worry about the amendments. However, we are now at this point, we look at amendments. That's what we have. So if we have to go back and amend a partnership return that's got 100 partners, now you've got 100 partners getting amended K ones, and now those 100 partners have to amend their 10 forties from that year. So you can see the exponential impact it'll have on amended returns, and right now the IRS is taking six months to process amended returns. At least that's what I've heard recently.
Daniel Hood (07:08):
Yeah, it's something like it.
Frank Sands (07:10):
They just don't have the personnel for it. So this is an issue. I think more guidance is needed in this area. And one of the problems we have with amended returns is, okay, look, you got a three year window to amend a return. Right now you can get credits from 2021 payroll, and the deadline for applying for those credits is April 15th of 24. Now the three year window on amending a 20 tax return ends in 24, and it ends on the date that you filed the return. So if you filed the return on four 15 and you got until four 15 to request credits, you could get into a situation where you receive credits after the three-year window for amendment has run, and we don't know what the IRS is going to do about that. The same thing applies for 21 credits. They have until 25 to get those applied for, and we're looking at the same thing. So we're pushing for some description or some additional guidance on this, but the IRS is so inundated with everything they have to do. It's very difficult for them to get this stuff out on what we would on a basis or a time basis that we would like to have it. Yeah,
Daniel Hood (08:45):
I mean IRS is, as you say, swamped and I want to talk a little bit about the IRS and its situation and how well it's doing, but we'll save that for little bit later. I do want to ask, as you said, there's no big tax laws, but there are these regulatory and sort of things for people to be paying attention to. You had alluded earlier to the BOI, the beneficial ownership information reporting requirements laundering sort of thing, where they're really requiring small businesses. They've exempted a lot of large businesses requiring small businesses to report who's the ownership, and it's on a very short timeline of 30 days. They gave an extension for new businesses and not an extension, a slightly slight extension, I guess you call it for new businesses formed in 2024. But otherwise, a lot of small businesses are going to get hit by that and your members work routinely. You're on the front lines of working with small businesses across the country. So what are you telling your members about the BOI reporting requirements?
Frank Sands (09:44):
BOI is a real different animal because it really isn't income tax reporting. So the first question we have to ask ourselves and our insurers is, okay, can we do this? Can we help people with filing these reports and coming into compliance with the requirements, reporting ownership interest and controls in an entity, whether it's a corporation or partnership, whatever, we're concerned that that would be considered the unlicensed practice of law. We can't do that, and our insurers tell us we don't cover the unlicensed practice of law.
(10:35):
So it gives us complication on, okay, are we as CPAs or are we not going to help our clients with this? Are we going to help them file these reports and come in compliance with the requirements or are we not? And it's largely going to be up to each individual CPA to decide whether they're going to do that or not. Well, we're telling our membership is the first thing you need to do is call your insurance company and get their take on it. If you decide to do this, you should have a separate engagement letter on it and make it real specific. One of the problems is, okay, you do the first report that gets it on record with FinCEN. Then if you have a change in that information that you reported, you got 30 days to correct it. Which means those clients that come into us during tax season and say, oh, by the way, I formed an LLC back last June. Okay, we got a problem.
(11:57):
And if you're going to offer this service, you've got to know that, okay, you've got an annual report and then you have got 30 day follow-ups every month and ask them, did this change? Because part of the information you put on there to identify yourself would be a driver's license. When does your driver's license renew? That's a change that would have to be reported. You've got a partnership with 100 partners. They come in and out that may require a change in reporting. So we're telling our members that if you're going to do this, you better be ready for all of these requirements and make sure that your insurer knows that you're doing it and you get a separate engagement letter if you decide not to. The very least we're telling our clients to do is send your clients a letter that would be obligated and A-I-C-P-A recently published a recommended format or template of a letter to send to your clients to inform them of this thing. Because a lot of people, a lot of businesses that are going to be affected by this aren't aware of it yet,
Daniel Hood (13:24):
And they're probably the ones that, even the ones that are like, well, I'll talk to my accountant when I go get my taxes done, which is just to listen. You described the requirements of it. They're insane. I mean, I'm just going to go ahead. I'm going on record as saying that are requirements of this. No one, the people who put this in place clearly have never run a small business and have no idea the capabilities of a small business to do this kind of compliance. Just nuts. The 30 day window every time there's a change in, as you said, your license gets renewed, it's crazy. But anyways, but the point is a lot of small businesses don't even know about the requirements and if they do, they're expecting their accountant to help them. So yeah, at least sending a letter saying, this is happening. We're not going to do it law as you say, we're worried about the practice of law, but we're letting you know about it. That seems to be, at the very least, would make a lot of sense because otherwise a lot of people will say, well, you're my accountant. Why didn't you tell me about this?
Frank Sands (14:21):
We occupy a space in our clients' lives that is because we know so much about our clients and are so closely related with information and their businesses, they kind of just assume that we're on top of all this stuff and we take care of it for them. And that's why when we get into these issues that engagement letters are so important.
Daniel Hood (14:49):
Yep, yep. Absolutely. Absolutely. As you say, talking to your insurer, any insurer will tell you that every time I talk to an insurer, probably the first thing they say is, do you have an engagement letter for this? Because it's such a huge issue. But as you say, it's this kind of thing where accountants may not be the right people to actually do this. I mean, they probably could, but they run into, as you say, the liability issues and is it practice of law and all that sort of stuff. It's also a huge burden because once you do it once, and I think that's your pointers, once you do it once, your clients are going to expect you to keep up with them and as you say, check every month to make sure that they haven't had some weird change that needs to get reported. So it's definitely something accountants want to let their clients know about, but may also want to step back from regardless of the liability issues. It's a big lift and the clients aren't necessarily going to want to pay for it. So anyway, something very serious to think about worth paying attention to. I want to dive, as we said, I want to talk a little bit about IRS performance and expectations there, but first we're going to take a quick break.
(15:51):
Alright, and we're back and we're talking with Frank Sands of Nick Pap and of Sans Gilland over the break. We were talking briefly, one of the things we didn't mention about the BOI is the penalties that come along and why it's such a serious issue. Maybe we just very briefly scare everybody who's listening with some details about those penalties. Kind of terrifying.
Frank Sands (16:10):
Thank you. The penalties right now, they're varied, but $500 a day up to a maximum of $250 and there's jail time between two and five years depending upon the level of violation and what the intent was and all that. Civil and criminal penalties. So it's pretty serious folks and these poor small businesses who aren't laundering money and aren't involved in anything illicit, and if they miss this, it can be really expensive.
Daniel Hood (16:54):
Right. I just want to clarify, I think you said you said two 50, but it's two 50 K, it's 250,000, right? Yes.
Frank Sands (17:01):
Okay. 250,000 thousand. Yeah, it's a big number.
Daniel Hood (17:05):
That's a big number. So worth warning your clients about, at the very least, as you say, you kind of got a responsibility to let your clients know that it's coming and to be aware of the seriousness of it, but whether you want to get involved in filling it out, that's a whole other issue. But at the very least, you want to make sure they know about it and they know how serious the repercussions can be.
Frank Sands (17:24):
And you mentioned filling out NCE in hasn't issued the form yet. Yeah,
Daniel Hood (17:30):
There's another thing. There's so much wrong with this whole area. Yeah, right. Yeah, they haven't completed it yet. So even if you wanted to help your clients, you couldn't yet. Other than again, and I don't think we can stress this enough to warn them, to let them know it's out there and they need to be aware of it. But I also, I want to talk a little bit more, I should say for those of you listening to this, we're recording before Christmas, before the holiday season. So as we talk about IRS performance and we talk about the potential for a shutdown and all that sort of stuff, we're a little bit earlier, so if things have changed between when we speak about this and when you listen, understand that, as I said, we're reporting recording it mid-December. But I want to talk a little bit about expectations in terms of IRS performance shutdown or no, obviously IRS performance and service levels have been an issue for the past several years. There's a lot of money that came into the IRS over the course of the last year from the Inflation Reduction Act. So I wanted to get your sense of, do you have any expectations in terms of IRS performance and service levels for the coming tax season? Again, sort of leaving, assuming there isn't a shutdown, if there is a shutdown that will change everything, but assuming there isn't, what are your expectations there?
Frank Sands (18:41):
Well, we know that we have experienced a little better response on phone calls, a little higher rate of answering. We hope that continues. The IRS is making a concerted effort in this area. We do have reports from our membership that while the phone may be answered more readily and more often, that the quality of information that you get from the person answering the phone may or may not be better than before. So you always got to keep that in mind. And remember that the IRS isn't held liable for advice they give over the phone, but that's an old standard. Everybody should know that what you hope, you get some guidance and maybe some help in those areas. One of the things that has come out with this, I think is first time abatement rules that okay, if you get hit with a penalty, you can get a first time abatement.
(20:08):
They've done great strides in making that easier to get. As a matter of fact, if you've got a registered POA, you can call 'em up on the phone at a special phone number and probably get it taken care of over the phone, and that's a great positive stride. So we would like to see more of that. Unfortunately, we've had problems, as I mentioned before, with amended tax returns, I think taking longer than six months. That's a personnel issue from what I understand. Taxpayer correspondence not being held, handled on a timely manner leading to erroneous letters coming out to the taxpayer. They're introducing new programs rapidly, and I think this is largely due to maybe pressure coming from Congress because Congress is in there saying, we gave you all this money. Where are the improvements? So the IRS is kind of caught between a rock and a hard place there. They want to roll these things out and demonstrate, yes, we are cognizant, we are doing these things, we're trying to make things better, but the backend suffers on how it actually works when it's implemented.
Daniel Hood (21:26):
Well, you mentioned, sorry, you mentioned staffing. I just always think that they hired thousands and thousands and thousands of people last year, but those people have to be trained. You talk about the quality of answers you're getting on calls and stuff like that. They're having tremendous attrition among their most experienced, longest serving people. The ones who can give you the best answers, who can give you the best service or whatever it is, and they're hiring all these new people that great, but you've got to train them. Those people have to learn, right? There's a learning curve before they're able to be significantly useful. So as you say, you can press 'em for immediate results, but in many of these areas you can't get immediate results. Just whatever you're doing, whether it's people or technology or those things, these systems need to be systems that people need to be trained and set up and vetted and all that sort of stuff.
Frank Sands (22:08):
That's an excellent point, Dan. Our information is it takes 'em four months to onboard somebody so they're effective and okay, you heard these things about, oh, they're going to hire 87,000 employees with all this money. They've only got 80,000 or 40,000 I think it is to begin with, and they've been trying to hire over the time period, but they've hired, what, a few thousand? So that hiring 87,000 IRS auditors, that just doesn't make sense. Okay. That's not the reality of it. And it is hard to bring these people on and they all have to be trained and the requirements of how the IRS has to operate and within the law and what the laws require, there's a lot of times when that isn't helpful for what the IRS needs to do and wants to do. So it is a concern.
(23:20):
One of the issues that I see, and with this new money, I wish there would've been more dollars allocated to technology. It's our understanding that the IRS is still using outdated computer programs and hardware and they have multiple systems and they got problems. Having those systems talk to one another. This creates additional problems, especially when they're trying to respond to taxpayer correspondence. It gives them problems with collections. If the collection divisions computer isn't updated with all the other information from other computers, you got a disadvantage to the employee that's trying to do the collection work. As I said, I wish they would've allocated more to technology to bring it up to date. So they have state-of-the-art, and it all talks together and everything is updated quickly so that the IRS has a hundred percent current information on any taxpayer. I think that would go a long way to making the employees more efficient and would lead to the need for less employees in certain areas. So I think their technology is being, well, apparently it looks like it may have taken a second seat, but I wish it was first.
Daniel Hood (25:00):
Yeah, yeah. Well this goes, there's two things, right? The IRS is famously terrible with technology has always been for decades has been everyone looks at their technology and goes, what are you doing there? But there's also, as you say, there's mandates put on them and the way that spending is set up or the way the funding is allocated, it's not necessarily specifically for technology and they get pressures to do things that have priorities that aren't necessarily the right ones. Technology should be a priority, as you say, it would solve a lot of their problems and ease up some of their other problems. But they're mandates and they're the things they're expected to do. They're sort of not always able to choose them, right? Because if they could, I think technology would be a smart priority for them to get set because if you could get a system like that in place, as you say, would solve a lot of problems and make a lot of things better.
(25:52):
Alright, well, but we'll keep an eye on things, how they go. We'll be talking about how it goes over the course of tax season. Fingers crossed that they're able to keep at least not to slide back below. They had during the pandemic had some serious issues as you would expect everybody did, but we're hoping that they'll, I think they were a little better last tax season. Let's hope they at least stay there and if not improve in next tax season. I kind of want to look beyond tax seasons as I keep talking about Nic Pap and its membership and the firms you work with. I think I want to say 35,000 members, but I may have that number wrong. I may be a little outdated, but you've got members of particularly small firms all across the country. What are the big issues you're seeing them facing as you talk to your membership? What are the things that are keeping them up at night beyond just the concerns about tax season and the IRS and BOI
Frank Sands (26:41):
Staffing shortages, and I think there's a lot of businesses facing that issue today. It's particularly difficult for CPA firms in public practice because of the shortage of qualified individuals. We have a recognition of that shortage in particular by the A-I-C-P-A and by everyone, and they're trying to do things to help with that shortage. A-I-C-P-A has something called the Pipeline acceleration plan, which reaches all the way down into the high school level to try to get more people to become accountants and go and get their CPA designation and be in public practice. But that doesn't help us right now. That's a long-term goal. So staffing shortages is particularly hard to deal with. I was recently exposed to that issue with a resignation and the new person starts today. They were hard to find. So the problem if you go short with staff of course, is getting all the work done for your clients and then if you throw BOI on top of it, that just makes the whole matter worse.
(28:20):
We are talking, I think I mentioned that we're telling our clients about BOI, or excuse me, our members about BOI and our clients. A-I-C-P-A also recently approved the new statement of standards for tech services effective on one one of 24. So in January we've got a whole new set of standards. It's not a whole new set per se. What they've done is they took existing standards and they codified 'em in the first two standards and then added two more to deal with issues and situations that weren't around back when the old standards were issued. So they've been updated and trying to deal with that and help with those various issues. The wisp requirement, the written information security plan requirement that comes from Graham Leach Act that's also on the front lines for our members. You got to have the written plan. As a matter of fact, I renewed my P 10 not too long ago and there's a question you got to answer yes or no if you have one. Now, luckily I got to answer that question, yes.
(29:45):
But yeah, a lot of small practitioners, I mean, I hear from some of our members here in Texas as well through the Texas Association of CPAs that they got this template and they call me up and they say, help me understand this thing. What is it that we got to have here? Exactly. So it's not necessarily an easy thing to get through, but once you've muddled through it and got yourself a plan written, then you're okay. And the only caveat is that if you've got things in the plan that require periodic follow-up, that you make sure you do it.
Daniel Hood (30:30):
It's one of those ones where hopefully everybody knows that they're supposed to have it. But then you say, the only way anybody's checking is when the IRS says, do you have one? And you check the box. And I think the worry is that a lot of firms will say, well, I just checked the box, but I'll get to it. I'll get to it. But at some point someone's going to go around to saying, show us your plan. And that's going to be maybe a little troublesome for firms that haven't yet got to it on their to-do list to put it that way. So excellent. Definitely the staffing is an issue. New standards always things to pay attention to. The wisp, everyone, we hear a lot of people talking about it, and I think at some point we will see people being required to produce 'em. So definitely worth muddling through them, as you say, trying to figuring them out. I want to talk a little bit, we've been talking about Nick Pap all through. I've been mentioning Nick Pap. What's going on there? What's going on at the group?
Frank Sands (31:21):
Well, we've got some things going on, some changes, and we're moving forward. Our annual tax symposium, which is held in November every year on Long Island, that's now an in-person event. Only a couple of years when it wasn't, but we're back to being in-person now and it's got new leadership. So we're looking for continued success with that three day seminar that we have. Our strategic planning committee is overseeing a new five-year plan for growth and improving support to our membership and other small practitioners. And it emphasizes outreach and trying to get the word out that the majority of public accountants in public practice in this country are small firms. And we're trying to get the word out that, Hey, Nick Pap is here. And that's what we concentrate on. The needs of the small firm and helping them. I mean, one of the things we're looking at, Dan, is coverage in case a sole practitioner gets sick, can we have our membership?
(32:52):
And we had one instance of that this year or last year already, where our membership stepped up to help somebody who had gotten ill and couldn't take care of his business. Our membership stepped up and helped him in that manner. And succession planning, that's another thing that we're going to be looking at to help in those areas. We're also looking to improve our relationship and expand our working relationship with the A-I-C-P-A and we'll be working with Carl Peterson who is in charge of their small firms area. So I know Carl, so I look forward to working with him on those matters. We're having an emphasis on outreach to like-minded professional organizations. And what this means is, I think we touched on it a little bit when we were talking earlier. I think we were not recording it at that time, but the Texas Association of CPAs was able to become an affiliate of Nic Pap because of our like-minded emphasis on small practitioners and small accounting firms.
(34:09):
So we're trying to take that experience and expand it and see if we can bring those benefits to other professional organizations that are like-minded. So I think that has some real potential there. We've also got college outreach that we're doing, and we have an active scholarship program. We've issued a few scholarships and we are continuing to do so, and we will be sending out notifications to individual colleges that say, we have this available for accounting majors, and so we should be getting some response from that. We have also kicked off a virtual chapter. We know that, okay, if we want to reach out to folks in Idaho and we're going to have a seminar in New York, there's a little gap there.
(35:14):
And in order for people to be able to tune in and stay in contact on a regular basis with Nick Pap and what we're doing and the information we had to disseminate to our members, we've started this virtual chapter. And so if people are, they want to right now, it's, if you want to get a feel for what Nic Pep does, join one of the virtual chapters meetings and see then if you are within a reasonable geographic location, you can join one of the actual chapters that we have and go to those meetings and get to network with your fellow professionals on a interpersonal basis. And if can, you're happy with being in Zoom for a chapter meeting. Hey, great, we've got it. We've got you covered.
(36:16):
And then of course, our last thing is we're preparing for our upcoming Washington DC trip in May. That should be an interesting exercise. It reminds me last year when we were down there, one of the things we talked about was the 10 99 K reporting, and we were talking to a legislative director, and I looked at him and I said, so you go to Martin Steakhouse with your fellow lds? And he says, yeah, once in a while we do. And I said, okay, there's 13 of you and you get a bill for $1,300 and you pick it up so they don't have to split the check because they won't, and you pick it up and then all 12 of your fellow LDS pay you a hundred dollars with Venmo. I looked at him, I said, do you know you're going to get a 10 99 K for that? And he said, what? Talking about, so I tell that story because we do get listened to now and then when we go down there,
Daniel Hood (37:27):
Now that trip is one of the high notes, one of the highlights of your year, but it's huge for your members and for everybody else who gets anything out of it. Both you bring your perspective to them and your member's perspective and your member's client's perspective is perhaps most important, right? All the hundreds of thousands, if not millions of small businesses you work with, bring that to Washington, but they also bring tremendous insights back to your memberships. So that is a really spectacular, super useful trip I think, for everybody concerned.
Frank Sands (37:56):
Yes, I agree. A lot of times the people that are in those positions that pass these laws and write the revenue procedures to implement the laws, they're not fully informed about what's happening in the actual world on the front lines where this stuff is being applied, and it's important to get that message back to them. And we don't just point out a problem, we come with recommendations. So very much similar to let's say the a IPA's recent letter to the IRS regarding Are you prepared for a shutdown? So it's all along in those same lines.
Daniel Hood (39:00):
Yeah, as we say, it's one of the great, and I think members and aren't always aware that big part of that value is taking their perspective back to Washington and helping Washington understand what's going on. They see the value of when you bring the information from Washington, but they need to know that you're also out there C clueing, the people inside the Beltway Inn as to what happens in the real world outside of the beltway. We could talk for a lot more about all this stuff, but I wanted to make sure we got a sense of people's sense of what Nic Pap is doing and all the many things you guys are, many services you provide and the value you bring to your members and the community as whole. But otherwise, I'll say Frank's hands from Nick Pap, thank you so much for joining us.
Frank Sands (39:43):
You're very welcome, Dan, and thank you for help for having me.
Daniel Hood (39:46):
And thank you all for listening. This episode of On the Air was produced by Accounting Today with audio production by Kelly Malone and Adnan k. Ready to review us on your favorite podcast platform and see the rest of our content on accounting today.com. Thanks again to our guest, and thank you for listening.