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Tax Review

A review note survives the season. It rarely survives the filing.

August 31, 2026

A paper note peels loose from a closed folder and drifts toward a wastebasket past a shelf of identical folders

A review note records the one thing a checklist can't — why a reviewer accepted a position, overrode a diagnostic, or dropped last year's aggressive treatment. Then the season ends, and most of that reasoning goes with it. Nothing requires otherwise: 26 CFR § 1.6107-1 obligates a preparer to keep a copy of the filed return for three years. It says nothing about the note explaining why the return looks the way it does.

3 years

How long 26 CFR § 1.6107-1 requires a preparer to retain a filed return — a duty that reaches the return, not the reasoning behind it

  1. Written

    A reviewer attaches a note to the line it explains — a judgment call a checklist wouldn't catch.

  2. Routed to the preparer

    The note travels inside whatever software the reviewer had open when they wrote it.

  3. Cleared

    The preparer responds, and the reviewer marks it resolved.

  4. Filed

    The return goes out. Nothing distinguishes a cleared note from one that was never written.

    What happens next season

    Unless someone carries it forward by hand, the note stays behind with this year's closed file.

The path a review note actually takes, from the moment a reviewer writes it to the moment the return it explains is filed.

31 CFR § 10.36 requires a firm to have adequate review procedures — a real, enforceable duty, but one about process, not about whether last April's reasoning is findable next April. Pernee attaches a review note to the return line it explains and keeps it there past the season that produced it, so the next reviewer finds the reasoning, not a closed file.

Review notes are one piece of a longer process

See how review notes fit into the full tax return review workflow, tier by tier.

Read the article

Give review notes somewhere to live past the season

See how Pernee keeps a reviewer's reasoning attached to the return line, across the seasons a firm actually revisits it.

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