The U.S. tax code runs about 4,000 pages. The Treasury regulations interpreting it run another 17,000. Adding the case law, revenue rulings, and IRS guidance brings the total practitioners need to keep current on to somewhere north of 75,000 pages, with substantive changes published nearly every week.
A small-firm or mid-firm generalist CPA, running 250 to 400 returns through a four-month busy season, cannot read all of that. They can read the high-volume changes (the rate tables, the standard-deduction adjustments, the most common credit forms) and they can rely on their tax software to flag the rest. The result is that the tax software becomes the de facto knowledge base. The software handles what it is configured to handle, and items that require a conversation, a structural decision, or a project to capture tend to slip.
The pattern shows up most clearly in three categories:
- Structural elections that require multi-year planning. S-corp election, C-corp choice for §1202 eligibility, accounting-method changes via Form 3115. These belong to the year-zero advisor, not the return preparer, and often nobody is occupying that role.
- Credits and deductions that require substantiation work. The §41 R&D Credit, cost-segregation studies, the §45L homebuilder credit, the §179D commercial-building deduction. The credit or deduction is the easy part; the substantiation is a project, and projects do not bill at the same rate as return prep.
- Time-sensitive transition rules. The §174A retroactive amend window, ERC backlog amends, IRA-era energy-credit phaseouts. The deadline is short, the rule is new, and many practitioners are still catching up.
A second-opinion review is a structured way to surface items in all three categories without disrupting your existing CPA relationship. It is also, frankly, useful as a forcing function: even when the review finds nothing material, the conversation with your current preparer about why they did not raise an item often produces a better working relationship.