The IRS announced that it will refund fees paid by tax return preparers from November 2011 to January 2013 to take the Registered Tax Return Preparer test. In Loving v. IRS, 742 F.3d 1013 (D.C. Cir. 2014), the court determined that the IRS did not have the authority to regulate or require testing for paid tax return preparers under Circular 230. Therefore, the IRS will refund the fees for the testing that occurred prior to the court’s decision. In light of the Loving ruling, which ended the regulation of paid tax return preparers, the IRS has developed a voluntary program for return preparers.