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Page 4 of 17 Fileid: … ons/P947/201802/A/XML/Cycle04/source 13:40 - 23-Feb-2018
The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.
Unenrolled return preparers may represent taxpayers scribed in (1) below, proof of authority to represent the
only before revenue agents, customer service representa- taxpayer.
tives, or similar officers and employees of the Internal
1. An individual. An individual can represent himself or
Revenue Service (including the Taxpayer Advocate Serv-
herself before the IRS and does not have to file a writ-
ice) and only during an examination of the tax returns they
ten declaration of qualification and authority.
prepared and signed prior to December 31, 2015. Unen-
rolled return preparers may not represent taxpayers be- 2. A family member. An individual can represent mem-
fore appeals officers, revenue officers, counsel or similar bers of his or her immediate family. Immediate family
officers or employees of the Internal Revenue Service or includes a spouse, child, parent, brother, or sister of
the Department of the Treasury. Unenrolled return prepar- the individual.
ers may not execute closing agreements, extend the stat-
3. An officer. A bona fide officer of a corporation (in-
utory period for tax assessments or collection of tax, exe-
cluding a parent, subsidiary, or other affiliated corpo-
cute waivers, or sign any document on behalf of a
ration), association, or organized group can represent
taxpayer.
the corporation, association, or organized group. An
If an unenrolled return preparer does not meet the re-
officer of a governmental unit, agency, or authority, in
quirements for limited representation, you may authorize
the course of his or her official duties, can represent
the unenrolled return preparer to inspect and/or request
the governmental unit, agency, or authority before the
your tax information by filing Form 8821. Completing Form
IRS.
8821 will not authorize the unenrolled return preparer to
represent you before the IRS. For more information, see 4. A partner. A general partner can represent the part-
Form 8821 and its separate instructions. nership before the IRS.
Annual Filing Season Program Record of Comple-
tion. Only unenrolled return preparers with a valid PTIN 5. An employee. A regular full-time employee can rep-
and who hold a record of completion for BOTH the tax re- resent his or her employer. An employer can be, but is
turn year (2015 or thereafter) under examination and the not limited to, an individual, partnership, corporation
year the examination is conducted may represent under (including a parent, subsidiary, or other affiliated cor-
the following conditions: Unenrolled return preparers with poration), association, trust, receivership, guardian-
the necessary record(s) of completion may represent tax- ship, estate, organized group, governmental unit,
payers only before revenue agents, customer service rep- agency, or authority.
resentatives, or similar officers and employees of the In- 6. A fiduciary. A fiduciary (trustee, executor, personal
ternal Revenue Service (including the Taxpayer Advocate representative, administrator, receiver, or guardian)
Service) and only during an examination of the tax year or stands in the position of a taxpayer and acts as the
period covered by the tax returns they prepared and taxpayer, not as a representative. See Fiduciary un-
signed. Unenrolled return preparers may not represent der When Is a Power of Attorney Not Required, later.
taxpayers, regardless of the circumstances requiring rep-
resentation, before appeals officers, revenue officers, Representation Outside the United States
counsel or similar officers or employees of the Internal
Revenue Service or the Department of the Treasury. Un- Any individual may represent an individual or entity, who
enrolled return preparers may not execute closing agree- is outside the United States, before personnel of the IRS
ments, extend the statutory period for tax assessments or when such representation also occurs outside the United
collection of tax, execute waivers, or sign any document States. See section 10.7(c)(1)(vii) of Circular 230.
on behalf of a taxpayer.
If an unenrolled return preparer does not meet the re- Authorization for Special Appearances
quirements for limited representation, you may authorize
the unenrolled return preparer to inspect and/or request The Commissioner of Internal Revenue, or delegate, can
your tax information by filing Form 8821. Completing Form authorize an individual who is not otherwise eligible to
8821 will not authorize the unenrolled return preparer to practice before the IRS to represent another person for a
represent you before any IRS personnel. For more infor- particular matter. The prospective representative must re-
mation, see Form 8821 and its separate instructions. quest this authorization in writing from the Office of Pro-
fessional Responsibility. However, it is granted only when
Practice denied. Any individual engaged in limited
extremely compelling circumstances exist. If granted, the
practice before the IRS who is involved in disreputable
Commissioner, or delegate, will issue a letter that details
conduct is subject to disciplinary action. Disreputable con-
the conditions related to the appearance and the particu-
duct includes, but is not limited to, the list of items under
lar tax matter(s) for which the authorization is granted.
Incompetence and Disreputable Conduct shown, later,
under What Are the Rules of Practice. The authorization letter should not be confused with a
letter from an IRS center advising an individual that he or
Other individuals who may serve as representatives.
she has been assigned a Centralized Authorization File
Because of their special relationship with a taxpayer, the
(CAF) number. The issuance of a CAF number does not
following individuals may represent the specified taxpay-
indicate that an individual is either recognized or author-
ers before the IRS, provided they present satisfactory
ized to practice before the IRS. It merely confirms that a
identification and, except in the case of an individual de-
Page 4 Publication 947 (February 2018)
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