CPA tax preparers lack a standardized, auditable framework to independently verify and document the substantive validity of third-party R&D credit studies before accepting them as support for a tax return they sign.

Existing R&D credit studies from outside providers may be polished but lack transparent, verifiable evidence of technical uncertainty, process of experimentation, and direct employee/expense linkage. Preparers face uncertainty about how much independent diligence is required under preparer penalty rules, with no tool to efficiently audit or validate these studies.