Representation before the IRS · Power of Attorney

Proper completion of power of attorney (Form 2848)

Most Form 2848 problems are line 3 problems: the IRS returns any power of attorney bearing a general reference. The rest of the form is a series of deliberate choices — what the representative may do, whose authority survives, who signs — each defaulting to something the taxpayer may not have intended.

The rule

Line 2 — the representatives (Reg. § 601.502; Instructions, line 2). Only individuals eligible to practise before the IRS may be named. More than four representatives requires “See attached for additional representatives” beside line 2 and an additional Form 2848. Enter each representative’s nine-digit CAF number, or “None” so the IRS issues one; the instructions note it is not the SSN, EIN, PTIN or enrollment card number and is not an indication of authority to practise. Enter the PTIN, if applicable, or “applied for” — with one hard case: unenrolled return preparers must possess a valid PTIN to represent a taxpayer. To have a representative receive copies of notices and communications, check the box under that representative’s name; there is a cap, in the figures table.

Line 3 — acts authorized. For the power of attorney to be valid, the taxpayer must enter the description of the matter, the tax form number (where applicable), and the year(s) or period(s) (where applicable). Consecutive years may be given with “through,” “thru” or a hyphen; fiscal years use YYYYMM; a short period takes its beginning and ending dates.

The prohibition is absolute: “Do not use a general reference such as ‘All years,’ ‘All periods,’ or ‘All taxes.’ The IRS will return any power of attorney with a general reference.” Representation applies only to the years or periods listed.

The current year and already-ended periods may be listed, and so may future periods — but the IRS will not record on the CAF future periods exceeding three years from 31 December of the year of receipt. Estate tax matters take the decedent’s date of death; employee plan matters take the plan number in the description. Where a form number or period does not apply — representation for a penalty, ruling requests, § 7623 award applications, CSP and VCSP matters, FBAR, FOIA — the taxpayer describes the matter specifically and enters “Not Applicable” in the remaining columns.

Line 4 — specific use. Checked where the authorisation is a one-time or specific-issue grant, or one not relating to a specific tax period (except civil penalties). Checking it changes the filing address — the form goes to the IRS office handling the specific matter.

Line 5a — additional acts authorized. Four acts require an express check because none is granted by default:

• Intermediate Service Providers. A representative may not use one to retrieve confidential tax information indirectly unless the box is checked; without it, the representative may still obtain the information directly through the IRS e-Services Transcript Delivery System. The instructions stress that these providers are privately owned, independent of and not affiliated with the IRS.
• Substituting or adding a representative. Not permitted unless the taxpayer gives written permission or delegates by checking the box. If authorised, the representative files a new Form 2848, signing it on the taxpayer’s behalf, with a copy of the written permission or the delegating form.
• Disclosure of returns to a third party. A representative cannot execute consents allowing the IRS to disclose to a third party unless specifically delegated.
• Signing the return. Reg. § 1.6012-1(a)(5) permits another person to sign an income tax return only on the three grounds in the figures table. The box must be checked and a prescribed statement entered citing 26 CFR 1.6012-1(a)(5) and the specific ground.

Line 5b. The taxpayer lists any act the representative is not to perform.

Line 6 — retention or revocation. A recorded Form 2848 generally revokes any earlier power previously recorded for the same matter; a specific-use or unrecorded one revokes only an earlier power on file with the same office for the same matters. To keep an earlier power, check the box and attach a copy. Filing a Form 2848 does not revoke a Form 8821.

Line 7 — signature. The taxpayer signs and dates, handwritten if filed by mail or fax — digital, electronic and typed-font signatures are invalid there, and an electronically signed form must be submitted online. On a joint return each spouse executes a separate Form 2848. A corporation or association is signed by an officer with legal authority to bind it, entering the exact title. A partnership requires all partners to sign with exact titles, unless one has authority under state law to bind it — then only that partner signs and a copy of the authorisation is attached.

Part II — declaration of representative. Each representative signs, dates and enters the designation under which they are authorised to practise, in the order listed on line 2. Designations: (a) Attorney — two-letter state and bar number; (b) CPA — state and certification number; (c) Enrolled Agent — enrollment card number; (d) Officer — title; (e) Full-Time Employee — title or position; (f) Family Member — the relationship, limited to spouse, parent, child, brother, sister, grandparent, grandchild, step-parent, step-child, step-brother or step-sister; (g) Enrolled Actuary; (h) Unenrolled Return Preparer — the PTIN; (k) Qualifying Student or Law Graduate — “LITC” or “STCP”; (r) Enrolled Retirement Plan Agent.

Current figures

How it works in practice

Line 3 is where forms die. “All years” is not shorthand the IRS tolerates — it will return any power of attorney with a general reference. Name the matter, the form number and the periods, using ranges where consecutive. Breadth comes from listing generously, not vaguely: “Income, 1040, 2021 thru 2026” is specific; “Income, 1040, all years” is returned.

Everything on line 5a is off by default. The Intermediate Service Provider box is most often missed, because a firm using commercial transcript software cannot pull the client’s data through it without that check — though the representative can always go direct through e-Services. Without the substitution box a representative cannot hand the matter on, and the alternative is a fresh Form 2848 from the taxpayer. The third-party disclosure box is the sharpest: a representative may not consent to the IRS releasing the client’s information to a lender, a court or anyone else unless specifically delegated.

Signing the return is narrower than it looks. The three grounds in Reg. § 1.6012-1(a)(5) are exhaustive, and convenience is not among them. The instructions also require the prescribed statement, naming which ground applies.

An agent is not a representative. Where the person signing is not the taxpayer’s representative, the instructions prescribe four steps: complete lines 1–3, check line 4, check the “Sign a return” box on line 5a with the prescribed statement plus “No other acts on behalf of the taxpayer are authorized,” and sign and date. The agent does not complete Part II, claiming no practice designation. If the agent e-files, the form is attached to Form 8453; if paper, to the return.

Signature rules are entity-specific and catch people. Joint filers need two forms, one each — a single Form 2848 signed by both does not appoint a representative for both, and the second is needed before acting for the other spouse. A partnership needs all partners unless one has binding authority under state law, with the authorisation attached. And the handwriting rule is absolute for mail and fax: an electronically signed Form 2848 must go online.

Part II order matters. Representatives sign in the order listed on line 2, and the designation letter is the claim of eligibility, each carrying its own identifying detail. Note that (f) Family Member is a closed list, and (h) Unenrolled Return Preparer is the designation for which a valid PTIN is mandatory, not merely “if applicable.”

How this has changed

The instructions carry a September 2021 revision date and were last reviewed on 30 April 2026. Three developments in that text are worth separating from the long-stable requirements.

First, the Tax Pro Account: the instructions now open by directing practitioners to the all-digital route, where “most requests record immediately to the Centralized Authorization File.” That is a change in latency, not law — Reg. §§ 601.503 and 601.504 are unchanged — but it is why an authorisation may be usable the same day.

Second, the signature split: a mailed or faxed Form 2848 must bear a handwritten signature, while an electronically signed one must be submitted online. Stated as a hard requirement, not a preference.

Third, the Intermediate Service Provider box, absent from older versions. It reflects the growth of commercial platforms between practitioners and IRS data, and the instructions are careful to say those providers are independent of and not affiliated with the IRS.

Two older features still catch candidates. Line 3 entries for the centralized partnership audit regime (BBA) require that phrase in the description column. And the Part II designation list skips several letters — a residue of categories removed over time, not an error in the form.

Exam focus

The most reliably tested rule is line 3: the matter description, the form number and the periods are all required, and a general reference gets the form returned.

Know that line 5a acts are not granted by default — Intermediate Service Provider access, substitution or addition, third-party disclosure consent, and signing the return. Know the three grounds on which an agent may sign under Reg. § 1.6012-1(a)(5), and that the 60-day absence is measured before the due date.

Know that joint filers need separate forms, that a partnership needs all partners unless one has binding authority under state law with the authorisation attached, and that a corporation is signed by an officer with authority to bind it, entering the exact title.

Know that the CAF number is not an indication of authority to practise, and that an unenrolled return preparer must hold a valid PTIN to represent.

Check yourself

1. A Form 2848 lists “Income, 1040, All years” on line 3. What happens? (A) The IRS records it for all open years (B) The IRS narrows it to the current year (C) The IRS returns the power of attorney (D) The IRS records it but limits it to three years Answer: C. The instructions state that the IRS will return any power of attorney with a general reference such as “All years,” “All periods,” or “All taxes.”

2. Which act does a Form 2848 grant without any box being checked on line 5a? (A) Consenting to disclosure of the return to a third party (B) Signing the taxpayer’s income tax return (C) Substituting another representative (D) None of these — each requires an express authorisation Answer: D. Each of the line 5a acts, including Intermediate Service Provider access, must be specifically authorised by the taxpayer.

3. On which ground may an agent sign an individual income tax return under Reg. § 1.6012-1(a)(5)? (A) The taxpayer is travelling for work (B) Continuous absence from the United States for at least 60 days before the due date (C) The taxpayer has authorised it in writing (D) The representative holds a valid PTIN Answer: B. The three grounds are disease or injury, continuous absence from the United States including Puerto Rico for at least 60 days before the due date, or specific IRS permission for other good cause.

4. A married couple filed jointly and both sign one Form 2848 naming one enrolled agent. Effect? (A) Both spouses are represented (B) Only one is; each must execute a separate Form 2848 (C) The form is invalid (D) Both are, if the agent countersigns Answer: B. The instructions require each spouse to execute his or her own power of attorney on a separate Form 2848.

5. What does an unenrolled return preparer enter in Part II under designation (h)? (A) A state bar number (B) An enrollment card number (C) A valid PTIN (D) A CAF number Answer: C. The instructions state that unenrolled return preparers must possess a valid PTIN to represent a taxpayer before the IRS.