Point.

Professionals are professionals because they demand of themselves a sense of perfection and an attitude for quality of performance. In 1977, partially as a reaction to governmental pressures, the concept of peer review was initiated to show the public that this profession is willing to do that which no other profession does--to monitor each other's performance and make the results public.

The endeavor was a huge success, so much so that, in 1989, the Private Companies Practice Section, in response to continuing comments from members, approached the Tax Division with the idea of a voluntary tax practice review for firms that had indicated an interest. The Tax Division had been considering the idea for a couple of years, and this was all the encouragement needed.

A task force was formed and a program was developed. Today, all practitioners submit to a peer/quality review of their accounting and auditing practice. It is only natural that the tax practice be reviewed as well. Firms then can be assured that the vast majority of their practice is reviewed for quality. Practitioners take pride in their work; a review assures them that this pride is deserved.

Mr. Voynich views VTPR "as a program that can only meet its apparent goals by becoming mandatory." I'm not sure what the "apparent goals" are, so it is difficult to respond. Quality control in the accounting and auditing practice was a voluntary program when first introduced to the membership. It became mandatory only when the profession decided it was in its best interests to make it mandatory. So, too, with VTPR; if it ever becomes mandatory, it will be when the profession so determines. Why is that "ill-conceived, ill-timed and a disservice to the AICPA membership"

I will not respond to the criticism relative to the MAS activities of AICPA members. As yet, there has been no suggestion that a review process should be created for those members desiring to use it. However, there is a growing demand by the public for CPAs to apply the attest function in areas other than financial statements. While I acknowledge that the accounting and auditing peer review process was a reaction of the profession to outside influences (namely, congressional hearings and publications), this does not make the process undesirable. Sometimes the profession progresses due to outside influences, and sometimes from internal ones. Doesn't that make us a stronger organization? Would anyone say that the practice of public accounting in this country is less focused on quality and service to the public with quality review than without?

Mr. Voynich argues that there are others who may be practicing in the tax area, unlike the audit area. The quality review process does not review solely the audit work of a practitioner; it also reviews the practitioner's compilation and review activities. There seems to be a concentration on the audit area only because those situations attract media attention, while compilations and reviews do not. Mr. Voynich would seem to object to a tax practice review process because it might put CPAs at a disadvantage vis-a-vis the competition. That's an interesting perspective. I have never felt that I was competing in tax practice with attorneys, enrolled agents or storefront preparers. CPAs offer tax services to the public just as they offer accounting services. The goal is to do the best job possible for clients. CPAs take CPE courses to improve their abilities, and conduct in-house meetings to discuss technical issues. A practice review is nothing more than an extension of the desire to be competent. Do CPAs need outside pressures to create a public need? Doesn't the public need constantly exist? The public is purchasing CPA services. They are entitled to the best CPAs can provide. That is a professional obligation. How is that "an ill-conceived internal need that may be harmful to practitioners and the AICPA"?

Individual firms are being criticized for conceivably using peer review of their tax practice as a marketing tool. Why? A firm should be able to market itself as it chooses as long as it stays within ethical constraints. The AICPA does not need an education program for the public. The public has little understanding of the Peer Review program that has been in existence for 17 years. How many bankers, lawyers or insurance agents are familiar with either the old Peer Review program or the current Quality Review program? Is a tax program any different? The AICPA does not need to incur the expense. Firms can do their own promotional work.

During the time I spent on the task force creating VTPR and the three years I spent on the Tax Practice Management Committee, I did not encounter any fellow practitioner who was aware of any professional standards in a tax practice. VTPR does not create any standards; it only provides suggested guidelines against which to measure one's activity. It is a device to improve one's tax practice activities, not to restrict them.

Mr. Voynich is concerned that the VTPR program may act to create standards of tax practice. I doubt that this will occur, but even if it does, is it so bad to have standards by which to live? Maybe there are so many claims against tax practitioners because there are so few standards. After all, standards are nothing more than guideposts. Normally, we seek guideposts; why, in this instance, should we fear them?

The fear of litigation will not go away; why worry about it? If a practitioner conducts himself professionally, he has little concern about claims being filed. During my tenure on the Professional Liability Insurance Plan Committee, the committee began monitoring the claims activity of peer-reviewed firms against those that were not reviewed. It is well documented that peer-reviewed firms have better claims experience than firms not reviewed. Procedures and practice to improve the quality of tax practice do not provide an atmosphere conducive to bringing claims. I have never found a situation in which increased quality was a catalyst for litigation. If it were, peer-reviewed firms would be spending most of their time in court.

We take pride in the three letters following our names, and in the work we perform and the clients we serve. How do we demonstrate that our pride and our professionalism are not self-aggrandizement? By fearlessly subjecting ourselves to outside review.