IRS Publication 947: Practice Before the IRS
Understand the formal IRS process for authorizing a professional to manage your tax matters, from granting representation rights to simple information access.
IRS Publication 947, “Practice Before the IRS and Power of Attorney,” is a guide for taxpayers who wish to authorize another person to represent them in dealings with the Internal Revenue Service (IRS). This publication outlines the rules governing who is qualified to act as a representative and details the specific authorization documents required to grant this authority. Understanding these guidelines is helpful for any taxpayer seeking professional assistance with audits, appeals, or collection issues.
Who Can Represent a Taxpayer Before the IRS
The IRS sets specific standards for individuals who can represent taxpayers, a practice governed by Treasury Department Circular No. 230. These regulations define a group of professionals with unlimited representation rights, meaning they can represent clients on any tax matter. This group includes Attorneys, who must be in good standing with a state bar, and Certified Public Accountants (CPAs), who must be licensed by a state board of accountancy.
Enrolled Agents (EAs) also have unlimited practice rights. EAs earn this credential directly from the IRS by either passing a comprehensive examination covering all aspects of the tax code or through specific experience working for the IRS. Unlike attorneys and CPAs, whose licenses are state-specific, an EA’s right to practice is federal, allowing them to represent taxpayers in any state.
The regulations also identify representatives with limited practice rights. Enrolled Actuaries and Enrolled Retirement Plan Agents can represent clients, but only on matters related to specific pension and employee benefit plan issues. Unenrolled preparers can gain limited rights by participating in the IRS’s Annual Filing Season Program. Completing annual continuing education allows them to represent taxpayers for the returns they prepared and signed, but this representation is restricted to dealings with revenue agents and customer service representatives.
Required Authorization Forms
The primary document to grant representation authority is Form 2848, Power of Attorney and Declaration of Representative. Filing this form allows the named individual to perform actions such as signing agreements and representing the taxpayer at conferences, hearings, and meetings. It effectively creates a legal agency relationship for tax matters.
A different form, Form 8821, Tax Information Authorization, serves a more limited function. This document does not grant power of attorney; it simply allows the designated individual to inspect and receive a taxpayer’s confidential tax information for specified tax years. A person named on Form 8821 cannot sign returns, negotiate with the IRS, or represent the taxpayer in any capacity. It is an authorization for disclosure only, often used by mortgage companies or financial institutions to verify income.
The taxpayer must provide their full name, address, and Taxpayer Identification Number (TIN), such as a Social Security Number (SSN) or Employer Identification Number (EIN). The representative’s section requires their name, address, and Preparer Tax Identification Number (PTIN). Licensed professionals must also include their license or enrollment number and sign a declaration stating they are authorized to practice.
In the “Tax Matters” section, the taxpayer must specify the scope of the authorization, including the type of tax, the tax form number, and the exact years or periods covered. Vague descriptions like “all years” are not accepted by the IRS. The most current versions of these forms are available on the IRS website.
Submitting Authorization and Post-Filing Procedures
Completed and signed Forms 2848 and 8821 must be submitted to the IRS. Tax professionals can upload these forms through the secure “Submit Forms 2848 and 8821 Online” portal. Forms can also be mailed or faxed to the IRS service center that corresponds with the taxpayer’s address.
The IRS enters the authorization into its Centralized Authorization File (CAF) system, a database of taxpayer representatives. The IRS assigns a unique nine-digit CAF number to each representative if they do not already have one. This number identifies the representative across all clients and should be used on future authorization forms.
After the IRS processes a Form 2848, it sends copies of all notices and correspondence for the specified tax matters to the representative. Processing a new authorization for the same tax matter automatically revokes a previous one. To keep both authorizations active, the taxpayer must attach a statement with the new form.
A taxpayer can end a representative’s authority by sending a written statement of revocation to the IRS service center where the original form was filed. This statement must include the taxpayer’s name and TIN, the representative’s name and address, and a declaration revoking the authorization. A copy of the notice should also be sent to the representative.