The Walton Firm

Protecting your ability to e-file. Preserving your practice.

When the IRS questions your suitability or moves to revoke your EFIN, your business can grind to a halt overnight. Bank products, software access, and client trust depend on your ability to e-file. At The Walton Firm—Exclusively Defending Tax Professionals—we respond fast, defend your record, and fight to keep you in the program.

What puts your EFIN at risk

Protecting your ability to e-file. Preserving your practice.

Continuous Suitability issues (criminal, credit, or compliance concerns; unresolved penalties; identity theft flags)
Business Information Accuracy problems (unreported ownership changes, locations, or responsible officials)
Data Security deficiencies (breaches, weak safeguards, shared logins, unencrypted storage)
Advertising & Conduct

Continuous Suitability issues (criminal, credit, or compliance concerns; unresolved penalties; identity theft flags)
Business Information Accuracy problems (unreported ownership changes, locations, or responsible officials)
Data Security deficiencies (breaches, weak safeguards, shared logins, unencrypted storage)
Advertising & Conduct violations (misleading promos, refund advance claims, fee disclosures)
EFIN Renewal/Reporting failures (inactive EFINs, outdated principals, lapse in annual tasks)
Association Risk (service-bureau or office-sharing ties to others under investigation)
Unauthorized Use (someone filed using your EFIN/PTIN without permission)

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Early warning signs

What to do in the first 24–72 hours

“Suitability” or “Monitoring” letter requesting records or explanations
Software locks or bank-product holds tied to your EFIN
IRS site visit or phone verification regarding your office, staff, or volumes
Client complaints, chargebacks, or a pattern of amended returns and credits

What to do in the first 24–72 hours

Stop the bleeding: Lock down credentials, rotate passwords, and restrict user permissions.
Preserve evidence: Export e-file logs, user access reports, bank-product reports, and software audits.
Centralize communications: Do not call agents off the cuff. Route all contact through counsel.
Stabilize operations: Prepare a paper-file/exten

Stop the bleeding: Lock down credentials, rotate passwords, and restrict user permissions.
Preserve evidence: Export e-file logs, user access reports, bank-product reports, and software audits.
Centralize communications: Do not call agents off the cuff. Route all contact through counsel.
Stabilize operations: Prepare a paper-file/extension plan and client messaging script.
Call defense counsel: Early intervention often determines whether you keep your EFIN.

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Documents we’ll gather fast

Current e-file application printout (principals/responsible officials, locations)
Software user roster + last-login/access logs
Data-security policies (WISP), breach logs, VPN/MFA proof, encryption settings
QC/due-diligence procedures, training sign-offs, internal audit results
Marketing/website screenshots, fee disclosures, RAL/RAC advertising
Client complaint log, refund advance usage stats, amended/credit claim patterns
Ownership changes, leases, and subcontractor/service-bureau agreements

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Our defense approach

1) Rapid Intake & Risk Map

Timeline of events, who did what, where data lives, and immediate compliance gaps.

2) Evidence Build-Out

E-file transmission logs, role-based access records, bank-product reports, client sampling, QC checklists, training/discipline records, and data-security artifacts.

3) Written Response & Legal Positioning

Point-by-point rebuttal to the IRS e-file office, demonstrating suitability and remediation; propose tailored corrective actions where appropriate.

4) Parallel Matter Control

Coordinate with OPR, CI, civil exam, or state revenue inquiries to keep issues from cascading.

5) Appeals & Reinstatement

If adverse action issues, pursue administrative appeal and reinstatement with a compliance plan the IRS can accept.

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Walton Wins

Service Bureau Sweep—EFIN Preserved: IRS scrutinized all preparers linked to a bureau under investigation. We proved our client’s independence, controls, and clean file history. Monitoring closed; no revocation.
Unauthorized Use—Reinstatement: Spiked volume from a remote user triggered suitability review. We documented credential abuse, implemented MFA/role-based access, and obtained reinstatement with conditions.
Advertising Compliance—Sanctions Avoided: Misleading refund-advance language drew an adverse notice. We overhauled disclosures and training; no EFIN loss, warning withdrawn after remediation.

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Frequently Asked Questions

Please reach us at taxteam@thewaltonfirm.com if you cannot find an answer to your question.

What’s the difference between EFIN revocation and PTIN suspension?

EFIN loss stops your business from e-filing; PTIN suspension targets you as an individual preparer. Many matters involve both—our job is to keep either from knocking you out of practice.

Can I keep filing while my EFIN is under review?

Often yes, until an adverse action is issued—but software or banks may place holds. We’ll stabilize operations (paper filing, extensions) while we fight the review.

How long do I have to respond?

Deadlines are tight (often 10–30 days). Responding comprehensively—and once—is critical. We handle the record and extensions where appropriate.

What if someone used my EFIN without permission?

We frame it as unauthorized use, not willful noncompliance, and pair that with concrete controls (MFA, least-privilege, user separation, audit trails) to support reinstatement.

Will fixing my website/ads help?

Yes—corrective action (accurate fee/advance disclosures, compliant testimonials, no “guaranteed refunds”) is often decisive in outcomes.

The Walton Firm advantage

EFIN Readiness Checklist (quick self-audit)

Exclusively Defending Tax Professionals—this is all we do.
Integrated Defense across e-file office, OPR, CI, and civil exam—so one response doesn’t harm you elsewhere.
Playbooks that Work—ready-made compliance kits (WISP templates, user-access policies, QC checklists) to satisfy suitability fast.
Nationwide Representation—we defend preparers, EAs, and CPAs across the U.S.

EFIN Readiness Checklist (quick self-audit)

MFA enforced for all users; unique logins—no shared credentials
Role-based access with least-privilege; monthly access review
Encrypted storage + VPN for remote work; device-lock and wipe policies
Written Information Security Program (WISP) and breach response plan
Updated e-file application (owners, locations, responsible officials)
Documented QC for credits (EITC/CTC/HOH/AOTC) + internal file audits
Accurate advertising & fee disclosures; compliant refund-advance language
Annual training with sign-offs; disciplinary steps for violations
Vendor/service-bureau agreements reviewed and on file
Incident/complaint log maintained; corrective actions documented

EFIN Revocation & Suitability Challenges

Protecting your ability to e-file. Preserving your practice.

Protecting your ability to e-file. Preserving your practice.

Protecting your ability to e-file. Preserving your practice.

What puts your EFIN at risk

Protecting your ability to e-file. Preserving your practice.

Protecting your ability to e-file. Preserving your practice.

Early warning signs

What to do in the first 24–72 hours

What to do in the first 24–72 hours

What to do in the first 24–72 hours

What to do in the first 24–72 hours

What to do in the first 24–72 hours

Documents we’ll gather fast

Our defense approach

Walton Wins

Frequently Asked Questions

The Walton Firm advantage

EFIN Readiness Checklist (quick self-audit)

EFIN Readiness Checklist (quick self-audit)

EFIN Readiness Checklist (quick self-audit)

EFIN Readiness Checklist (quick self-audit)

EFIN Readiness Checklist (quick self-audit)

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