SECTION 2. BACKGROUND

.01 Pursuant to section 6011(e)(3), § 301.6011–7 implements the requirement that specified tax return preparers file individual income tax returns electronically if they prepare and file the returns for taxpayers. Under section 6011(e)(3)(B) and as further defined in § 301.6011–7(a)(3), a specified tax return preparer means, with respect to any calendar year, any tax return preparer within the meaning of section 7701(a)(36) and § 301.7701–15 who prepares any individual income tax return unless such tax return preparer reasonably expects to file 10 or fewer individual income tax returns in the calendar year, and if a person who is a tax return preparer is a member of a firm, that person is a specified tax return preparer unless the person’s firm members in the aggregate reasonably expect to file 10 or fewer individual income tax returns in a calendar year. Solely for the 2011 calendar year, a tax return preparer will not be considered a specified tax return preparer if the preparer reasonably

1 Filers are advised that although the instructions to the FBAR form are being revised in light of the final FBAR regulations, the data items appearing in the body of the FBAR form remain unchanged.

April 25, 2011 725 2011–17 I.R.B.

this revenue procedure will apply to undue hardship waiver requests for calendar year 2012 and thereafter. .02 Documenting a Taxpayer’s Choice to File Return in Paper Format . The provisions of this revenue procedure that explain how tax return preparers and specified tax return preparers can document a taxpayer’s choice to file an individual income tax return in paper format are applicable immediately.