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Notice 2011-6: Supervised Preparers and Non-1040 Preparers

All tax return preparers must have a PTIN. PTIN applicants must provide information about whether they are supervised and whether they prepare Form 1040 series returns.

Who is a Supervised Preparer?

Supervised preparers are individuals who do not sign, and are not required to sign, tax returns as a paid return preparer but are:

  • Employed by attorney or CPA firms OR
  • Employed by other recognized firms that are at least 80 percent owned by attorneys, CPAs, or enrolled agents

AND

  • Who are supervised by an attorney, certified public accountant, enrolled agent, enrolled retirement plan agent, or enrolled actuary who signs the returns prepared by the supervised preparer as the paid tax return preparer

When applying for or renewing a PTIN, supervised preparers must provide the PTIN of their supervisor. The supervisor’s PTIN must be a valid and active PTIN.

Supervised preparers may NOT:

  • Sign any tax return they prepare or assist in preparing
  • Represent taxpayers before the IRS in any capacity
  • Identify themselves as a Circular 230 practitioner

Who is a non-Form 1040 series Preparer?

Non-Form 1040 series preparers are individuals who do not prepare, or assist in the preparation of, any Form 1040 series tax return or claim for refund, except a Form 1040-PR or Form 1040-SS, for compensation.

When applying for or renewing a PTIN, non-Form 1040 series preparers must certify that they do not prepare, or assist in the preparation of, any Form 1040 series tax return or claim for refund, except a Form 1040-PR or Form 1040-SS, for compensation.

Non-Form 1040 series preparers may:

  • Sign any tax return they prepare or assist in preparing
  • Represent taxpayers before revenue agents, customer service representatives, or similar officers and employees of the IRS (including the Taxpayer Advocate Service) during an examination if the individual signed the tax return or claim for refund for the taxable year under examination

Non-Form 1040 series preparers may NOT:

  • Prepare or assist in preparing any Form 1040 series tax return or claim for refund, except a Form 1040-PR or Form 1040-SS, for compensation
  • Identify themselves as a Circular 230 practitioner

Additional Resources

Page Last Reviewed or Updated: 31-Dec-2013