Ckenefick wrote:To that point, you totally misconstrue what the AICPA has said.
I'm not misconstruing what the others are saying. They're saying, quite clearly, that if you have a client who files a Schedule C, E or F, and you don't file Form 3115 with their 2014 return to adopt the repair regulations, you've violated Circular 230. See, for example, “Implementing the new tangible property regulations”, an article published in the Journal of Accountancy (“if a CPA files a federal tax return for 2014 for a client without a Form 3115 or certain election statements, the CPA could be in violation of Circular 230 and subject to disciplinary action.”).
All I'm saying is that with several well-respected tax professionals out there saying that the failure to file Form 3115 to adopt the repair regulations is a Circular 230 violation, and you on the other side saying that filing Form 3115 with a zero IRC §481(a) adjustment is a Circular 230 violation, my choice is in between --- file the form.