945 PTIN

[Zoey]

I may be getting caught up on a technicality, but I am a sole-proprietor TPA firm. My fees are not like most TPA's. I do not charge to prepare the Form 945 (or 1099's for that matter). But I do prepare the Form 945 and 1099's for a few of my clients. The technicality that I am getting caught up on is "paid preparer". Since I am not technically paid to prepare it, do I still need to file for a PTIN?

Thoughts?

Thanks so much!