 The IRS had indicated that the new rules would have applied to all kinds of federal tax returns, including income taxes and payroll taxes.A new continuing education requirement of 15 hours per year would have been imposed on tax return preparers (except for CPAs, attorneys, enrolled agents, and a few others).In 2013, however, the United States District Court for the District of Columbia struck down most of these rules in the "Loving" case, holding that the Internal Revenue Service had no authority to require competency exams for tax preparers.