- 21.3.7.1 CAF Processing of Third Party Authorizations
- 21.3.7.2 The Centralized Authorization File (CAF)
- 21.3.7.3 CAF Function
- 21.3.7.4 Timely Processing
- 21.3.7.5 Third Party Information CAF Numbers
- 21.3.7.6 Updating CAF Records
- 21.3.7.7 CAF Research
- 21.3.7.8 Third Party Research
- 21.3.7.9 Authorizations Recorded on CAF
- 21.3.7.10 Form 2848 Power of Attorney and Declaration of Representative
- 21.3.7.11 Form 8821, Tax Information Authorization
- 21.3.7.12 Form 706, U.S. Estate Tax Return, Processing
- 21.3.7.13 Ineligible Level H Third Party Form 2848
- 21.3.7.14 Form 944 Processing
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This section of provides guidance to employees who record third party authorization information onto the Centralized Authorization File (CAF).
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See IRM 2.3, IDRS Terminal Responses,IRM 2.4, IDRS Terminal Input, and IRM 21.1.2.4.2, Unpostable IRMs, for information regarding the mechanics for completing certain actions. Reference Document 6209, ADP and IDRS Information, when researching issues such as Master File tax codes, filing requirements, etc.
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For representative authentication over the phone refer to IRM 21.3.10.2 Authentication and Disclosure Guidelines for practitioner authentication.
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A third party authorization is a signed document and/or an oral statement made, by a taxpayer, granting a third party the authority to perform specified acts relative to specific tax matters on behalf of the taxpayer. Third party authorizations include a power of attorney, written tax information authorization, non-written tax information authorization, oral disclosure consent, third party designee (aka Checkbox), estate tax return power of attorney, or an e-services disclosure authorization.
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The term "representative" applies to a power of attorney; the term "appointee" applies to a tax information authorization. The term "designee" applies to the Oral Disclosure Consent (ODC) terminology and Third Party Designee shown on the return.
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Information on disclosure authorizations is found in IRM 11.3.2, Disclosure to Persons with a Material Interest, and IRM 11.3.3, Disclosure to Designees and Practitioners. IRM 21.3.1, Taxpayer Contacts Resulting from Notice Issuance, contains guidelines for preventing unauthorized disclosure when assisting taxpayers and third parties.
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For information on powers of attorney, see IRS Publication 947, Practice Before the IRS and Powers of Attorney, Treasury Department Circular No. 230 Regulations Governing the Practice of Attorneys, Certified Public Accountants, Enrolled Agents, Enrolled Actuaries, and Appraisers Before the IRS, and Publication 216, The Conference and Practice Requirements, 26 CFR, Part 601, Subpart E.Publication 470, Limited Practice Without Enrollment, containing information pertaining to unenrolled return preparers and IRM 21.1.3.14, Operational Guidelines Overview, which provides information regarding enrolled agents.
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Authorization information pertaining to most federal tax matters is maintained on the Centralized Authorization File (CAF). IDRS provides nationwide access to CAF information. See IRM 2.3,IDRS Terminal Responses, and IRM 2.4,IDRS Terminal Input. Refer to Document 6209, ADP and IDRS Information, when researching issues such as Master File (MF) tax codes and filing requirements.
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The CAF contains:
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Minimal taxpayer information (name and TIN). Taxpayer address and phone information are not processed on the CAF.
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Third party name and address information. Telephone and fax number may be present.
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A summary of the types of tax and tax period(s) and the third party's name(s), CAF number(s) and type(s) of authority granted for each period.
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The CAF maintains an electronic record of an authorization. For purging schedules, see IRM 21.3.7.12(4). An authorization, continuing in force, may be re-recorded on the CAF at any time. The authorization must contain a clear request to re-record the authorization and current dated signatures to evidence current intent.
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Up to fifty third parties can be recorded on the CAF per tax period and per type of authorization ( Form 2848/706/8821). Capacity was expanded to accommodate large corporations.
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Only two third parties can be designated to receive notices; only one representative can receive refunds per tax module.
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The CAF records up to three future years. Compute this by adding three future years to the current calendar year. For example, if the current calendar year is 2008, all periods through December 31, 2011, can be recorded to the CAF.
Note:
For eligible periods for recording onto the CAF, go to December 31 of the year of input and add three years. For example, input date is January 15, 2008. Taken to December 31 and adding three years is December 31, 2011. In this example, all tax periods ending December 31, 2011 or prior can be recorded to CAF.
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Authorizations submitted electronically through Disclosure Authorization (DA) are recorded directly onto the CAF database and require no manual input. DA will:
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Allow only complete authorizations to be transmitted to the CAF
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Prompt the user when required fields are blank
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Allow only one representative ( Form 2848, Power of Attorney and Declaration of Representative) to receive a refund
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Allow only two third parties to receive copies of notices
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Not allow an unenrolled return preparer to receive a refund or sign on behalf of the taxpayer
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Prompt the user to submit a paper Form 2848, Power of Attorney and Declaration of Representative, or Form 8821, Tax Information Authorization, when special circumstances apply
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The processing of all third party authorization requests submitted on Forms 2848 and/or 8821 are centralized in two SB/SE sites, Ogden Accounts Management Campus (OAMC) and Memphis Accounts Management Campus (MAMC), with international processing remaining in Philadelphia Accounts Management Campus (PAMC).
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The public is advised to submit authorizations to the CAF Units per state mapping which follows this general rule:
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Taxpayer resides west of Mississippi - route to OAMC
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Taxpayer resides east of Mississippi - route to MAMC
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International taxpayers - route to PAMC
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Exception: Arkansas to MAMC
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Exception: Louisiana to MAMC
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For internal routing purposes, IRS employees outside the CAF function forward authorizations received, and which qualify for recording, to the CAF Units within a recommended 24 hours of receiving function validating information on form as follows:
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IRS offices west of the Mississippi fax to OAMC
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IRS offices east of the Mississippi fax to MAMC
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International receipts fax to PAMC
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If receipts are in bulk, e.g., received in a campus other than those listed above, ship overnight to the CAF Units.
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The CAF Team that receives the authorization establishes it on the CAF .EXCEPTION: International forms received in Ogden or Memphis should be forwarded to the Philadelphia CAF Function.
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CAF Unit addresses and fax numbers are:
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Memphis Address:
Internal Revenue Service
PO Box 268, Stop 8423
Memphis, TN 38101-0268
Fax number 901-546-4115 -
Ogden Address
Internal Revenue Service
1973 N Rulon White Blvd. MS 6737
Ogden, UT 84404
Fax number 801-620-4249 -
Philadelphia
Internal Revenue Service
International CAF DP: SW-311
11601 Roosevelt Blvd.
Philadelphia, PA 19255
Fax number 215-516-1017
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It is recommended that Internal Revenue Service personnel outside the CAF Units forward power of attorney and tax information authorizations to the CAF within 24 hours of receiving function validating the information on the form to ensure timely processing of authorizations.
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Receipts in the CAF Units are processed within the following time frames (excluding weekends and holidays):
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24 hours from receipt in the CAF Unit for priority faxes originating from Practitioner Priority Services (PPS), the Taxpayer Advocate Service (TAS), and large corporations
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48 hours from receipt in the CAF Unit for all other fax receipts
Note:
If a fax is received on a Monday, the 48 hours concludes at close of business on Wednesday.
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5 business days from receipt in the CAF Unit for mail and routed receipts with day received counted as day zero
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Immediate input for OTIA requests
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Immediate input for authorizations successfully transmitted through DA
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All submissions must, at minimum, evidence the date of receipt whether automated or manually date-stamped.
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When fax receipts are date and time stamped by the fax machine, no further action is required to evidence receipt. Otherwise fax receipts, received before 2:00 p.m. local time, are considered received on the current date. Documents received after 2:00 p.m. local time, are considered received the next day.
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When unusual circumstances arise, e.g., bulk receipts in significant volumes (e.g., over 100 receipts from any one source or operation), or which result from systemic disruption (IDRS or CAF "down cycles" or "mini-peak" periods), priority is given to backlogged work. CAF Unit Management will consider program demands and available resources, and determine what is a reasonable period of time in which to accomplish the necessary actions. If processing exceeds 10 additional business days beyond the normal processing time frame, Headquarters Analysts are contacted for potential re-routing of work.
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A unique, identifying CAF number is assigned to each third party for whom a record is established.
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A third party can request multiple CAF numbers in order to differentiate between multiple office addresses. The Second Name Line may be used to indicate "Location 1" , "Location 2" , etc.
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Requests for multiple locations or CAF numbers must be received as separate correspondence. The request must contain:
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Third party name, name variations and aliases
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Existing CAF numbers and corresponding address(es)
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A request for additional CAF number(s) and corresponding address(es)
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Enrollment numbers are no longer required or any other reference in the IRM to enrollment
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A third party dated signature
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A third party can also request multiple CAF numbers in order to differentiate between related entities, e.g., "John Smith, CPA" versus "The Firm of John Smith, CPA" and/or "the Firm of John Smith, Atty" . Care must be exercised in distinguishing between the CAF number for the individual and CAF numbers for the business entities.
Note:
When assigning CAF numbers DO NOT enter titles in the suffix field. (i.e. Atty, CPA, Unenrolled, EA, etc.)
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Prior to assigning a CAF number to a third party, ensure a CAF number is not already assigned by researching Command Code (CC) RPINK using the third party's name.
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If a name matches the representative but the address is different, call the representative and verify whether or not the CAF number is theirs.
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If a CAF record does not exist, add the third party and assign a CAF number by taking the following actions:
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Input CC RPINK.
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Input CC FRM3P to initiate the ADD3P screen.
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Enter required third party data.
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A message will be returned "Representative Added NNNN-NNNNNR."
Note:
When assigning CAF numbers DO NOT enter titles in the suffix field. (i.e. Atty, CPA, Unenrolled, EA, etc).
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There are certain rules which apply to assigning CAF numbers:
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You cannot change a CAF number to one that already exists (belongs to another third party). Error message "CAF NUMBER ALREADY EXITS" displays.
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The number must begin with a valid 2-digit combination (20, 32, 50, 80, 26, 78, 65, 12, 43, 90, 01, 02, 03), If an invalid 2-digit combination is used, you receive error message "ERROR ON NEW CAF NUMBER" .
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the number you are changing cannot be greater than that most recently assigned by the system (ADD3P). If it is, you receive error message, "NEW CAF NUMBER IS GREATER THAN LAST ASSIGNED CAF NUMBER" .
Note:
If a CAF number is assigned in error, use Letter 1727C, Power of Attorney Representative Number, or other applicable correspondence to inform the third party that a CAF number has been assigned to them in error.
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CAF function may provide a third party with their assigned CAF number upon request. After authenticating the identity of the third party using CC RPINK and verifying at least two elements of the third party record, e.g., name, address or phone, the CAF examiner may disclose the third party's CAF number either by phone, fax or Letter 1727C, Power of Attorney Representative Number.
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If the correct CAF number can't be identified through research, reject back to the representative for clarification.
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If multiple CAF numbers are identified for the same representative, make contact with the representative to verify that the numbers should be merged. Consolidate to one number according to the following priority:
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If the third party requests a specific number issued, consolidate to the number requested.
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If the third party identifies an error but does not request a specific number, consolidate all numbers to the first number assigned, based on the earliest dated CP 547, We Assigned You a Centralized Authorization File (CAF) Number.
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If the CAF numbers were assigned on the same date, consolidate to the lowest number assigned.
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Make a print for the CAF Merge File and give it to the team lead.
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Use Letter 1727C, Power of Attorney Representative Number, to inform the third party of the correct CAF number, or you may advise the third party by phone or fax.
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The CAF Team receiving the request completes the appropriate consolidating actions.
Note:
Both name controls must match in order to complete the merge. If they do not match you will need to use CC KAFRMT to fix the incorrect name.
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Input CC CFINK, CAF number and press <PG UP> or <Page Up> key to transmit. Research CC RPINK if number is not known.
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Input CC KAFRMR and press <PG UP> or <Page Up>key to transmit.
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CC UPNCF is received.
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Put the name control and CAF number you want to keep and press transmit.
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Input CC CFINK, CAF number and press <PG UP> or <Page Up>key to transmit.
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Input CC KAFRMR and press <PG UP> or <Page Up>key to transmit.
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CC UPRCF is received.
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Enter the desired CAF number in the appropriate field at the bottom of the screen.
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There are certain rules which apply to merging off CAF numbers:
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You cannot change a CAF number to one that already exists (belongs to another third party). Error message "NEW CAF NUMBER ALREADY EXISTS" displays.
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The number must begin with a valid 2-digit combination (20, 32, 50, 80, 26, 78, 65, 12, 43, 90, 01, 02, 03). If an invalid 2-digit combination is used, you receive the "ERROR ON NEW CAF NUMBER" message.
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The number you are changing cannot be greater than that most recently assigned by the system (ADD3P). If it is, you receive error message, "NEW CAF NUMBER IS GREATER THAN LAST ASSIGNED CAF NUMBER."
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This section provides procedures for updating CAF records and when they apply.
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A practitioner who is updating the address that he/she uses on the CAF may, but is not required to, complete a new Form 2848 or obtain the signatures of his/her clients.
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Representative addresses will be updated in the following situations:
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Form 2848, Power of Attorney and Declaration of Representative, or Form 8821, Tax Information Authorization, and box two is checked.
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Signed and dated correspondence is received specifically requesting a change to the third party address.
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Representative calls the POA telephone help line and can fax a signed and dated request.
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To update the representative address, take the following actions:
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Input CC CFINK with CAF number and press <PG UP> or <Page Up>key to transmit. Research CC RPINK if number is not known.
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Input CC KAFRMR and press <PG UP> or <Page Up>key to transmit.
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CC UPRCF is received. Overlay appropriate fields with correct information.
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Press <PG UP> or <Page Up>key to transmit after Source Document Locator Number (SDLN) field.
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Only when correspondence clearly indicates a taxpayer name change:
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Input CC CFINK with TIN and press <PG UP> or <Page Up>key to transmit.
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Input CC KAFRMT and press <PG UP> or <Page Up>key to transmit.
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CC UPTCF is received. Verify name control information and overlay fields with updated information (e.g., name control, etc.).
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Press <PG UP> or <Page Up>key to transmit after SDLN field.
Note:
The actions outlined above change the taxpayer's name only on the CAF record. If the taxpayer wishes to change his/her name or address of record with the IRS, he/she must complete and submit Form 8822, Change of Address.
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If the taxpayer name on INOLE is spelled incorrectly, make a copy of the form and route the copy to Entity. Attach a copy of Form 2848, Power of Attorney and Declaration of Representative, to the printed INOLE screen.
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Proper research assists in preventing unpostable transactions and ensures proper information is sent to the taxpayer's Master File account.
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The following sections describe "strings" or sequences of research CCs required prior to the input of data. This is minimum research. Additional research may be required.
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Taxpayer research is conducted to assist in perfecting an authorization for processing. Research must be conclusive or the authorization is rejected.
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Use CC CFINK to determine if the authorization is already on file and avoid duplicate input.
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If the taxpayer's TIN is not on the authorization, use the following Command Codes (CC):
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NAMES/NAMEI - queries the National Accounts Profile (NAP) for name and address data, to determine the TIN when the authorization is for individual taxpayers. Either the primary or secondary taxpayer's name can be used.
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NAMEE/NAMEB- queries the NAP for name and address data, to determine TIN when authorization is for business taxpayers including employee plans.
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If the authorization has a TIN but is missing other taxpayer entity information, verify the name control, filing requirements and fiscal year month (FYM) and/or name line, using the following CCs:
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INOLE/BMFOLE & IMFOLE - displays Master File entity data. The CC definer determines the kind of data requested. If the primary TIN is unknown, a request can be made using the secondary taxpayer's TIN.
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ENMOD - if the account is on IDRS, use this CC to verify existing CAF indicator code.
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INOLEP - displays plan numbers and filing requirements for Form 5500. If the filing requirements indicator is blank, there is no filing requirement. Letters "X" , "Z" or "T" confirm filing requirements exist.
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EMFOLI - displays the plan number, the year and document locator number of filed returns.
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IMF/BMF account research CC string includes:
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INOLES - verify taxpayer name, entity, and filing status (IMF only) information.
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IMFOLI/BMFOLI - identifies tax periods with filings.
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Research using CC INOLE and ENMOD for cross reference Employer Identification Number (EIN) when Business Master File (BMF) MFTs are requested.
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Use Command Code (CC) RPINK to research a third party's record by name
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Use CC CFINK to research a third party's records by CAF number.
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Authorizations recorded on the CAF are generally submitted on Form 2848, Power of Attorney and Declaration of Representative, Form 706, U.S. Estate Tax Return, and Form 8821,Tax Information Authorization. Form 2848, Power of Attorney and Declaration of Representative, and Form 8821, Tax Information Authorization, can be input directly to the CAF by qualifying representatives via the Internet using the Disclosure Authorization (DA) program.
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When authorizations are submitted to the CAF Teams for recording, the information presented is input at "face value" . CAF examiners ensure all essential elements to an authorization are present. CAF examiners do not verify the credentials or practice status of a party listed as a representative on Form 2848, Power of Attorney and Declaration of Representative .
Note:
If the TE identifies suspicious information, refer to the lead to determine if the form should be processed, rejected or referred to TIGTA, CI or OPR.
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Below are the essential elements of an authorization. If an essential element is not present, completely absent, or missing, the document must be returned to the taxpayer.
Note:
For International CAF missing/incomplete authorizations contact the taxpayer's representative.
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Clear identification of the taxpayer, e.g., name, address, taxpayer identification number (the presence of two of the three elements is sufficient
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Clear identification of the third party, e.g., name and address (CAF number is not required). For multiple representatives, only one date is required on Form 2848,Power of Attorney and Declaration of Representative .
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Specific tax matter(s) - type of tax and period(s) (the form type is not an essential element). If information is shown in the type of tax or form type, the authorization is valid. Example: Authorization shows employment taxes under type of tax and tax form field is blank.
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Taxpayer's dated signature.
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For Joint IMF taxpayers, only one date is required on Form 2848, Power of Attorney and Declaration of Representative.
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For joint IMF taxpayers only, one signature and date is required on Form 8821, Tax Information Authorization.
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A thumbprint or X with a witness signature is acceptable.
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The date for both the taxpayer and the representative must be within 45 days for domestic authorizations and within 60 days for authorization from taxpayers residing abroad.Exception: if the taxpayer's dated signature is most current there is no time frame requirement.
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The sequencing of dated signatures is not critical although the taxpayer generally signs first, granting the authority then the representative signs, accepting the authority granted
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Process each taxpayer as a separate transaction. If information is missing for one representative, timely process all other representatives listed prior to rejecting with Letter 861C, Power of Attorney (Form 2848, Power of Attorney and Declaration of Representative) Incomplete for Processing, or other applicable correspondence. Indicate processednext to the representative(s) input to the system.
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Forms 8821, Tax Information Authorization, for the purpose of addressing tax matters, do not have to be received within 60 days of the taxpayer's dated signature. See IRM 11.3.3.1.1(4), Disclosure to Designees and Practitioners . The taxpayer must sign and date a TIA. The third party is not required to sign a TIA.
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A Power of Attorney (POA) authorization must contain required elements to be valid; however, the valid authorization may not be processable to the CAF system. Valid authorizations may not identify specific types of tax which are necessary for processing. Even though the authorization is not processable, it does not mean it is invalid.
Note:
Specific issues are not processed to the CAF system. A properly completed, dated and signed Form 2848 is still considered a valid authorization. The representative must be afforded all authorizations allowed by the taxpayer on the Form 2848.
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This section provides procedures regarding the return of authorizations when information is missing or incomplete. In distinguishing when an authorization must be returned to the taxpayer and when it may be returned to the third party, remember that only the taxpayer may grant the authority and certain information must come from the taxpayer.
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If essential elements 1-5 are not present, the document must be returned to the taxpayer. If essential element 6 is not present it must be returned to the representative. Refer to IRM 21.3.7.10.1 and 21.3.7.11.1 for a list of essential elements.
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If information is missing for one or more of the taxpayers or representatives and information is complete for others, timely process the processable taxpayer(s) or representative(s) listed prior to rejecting for the missing information. If a form is only partially processed, annotate "Processed" next to the name and address of the entity processed.
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When an authorization does not contain certain essential elements, the authorization is not acceptable to the IRS and the authorization must be returned to the taxpayer.
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Taxpayer is not clearly identified - must have at least two of three elements (name, address or TIN).
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Third Party is not clearly identified - must have at least two of three elements (name, address or CAF number).
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Must have taxpayer's signature and date (includes screen prints from e-services Disclosure Authorization).
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If the Form 2848, Power of Attorney and Declaration of Representative, is received on a joint account and the signature is missing for one taxpayer, timely process the other taxpayer listed prior to rejecting with Letter 861C, Power of Attorney (Form 2848, Power of Attorney and Declaration of Representative ) Incomplete for Processing, or other applicable correspondence. NotateProcessed on the form next to the taxpayer input to the system.
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No information is entered for tax matter(s), e.g. all of the following fields are blank, type of tax, tax form number, and year(s) or period(s).
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For incomplete Form 2848, Power of Attorney and Declaration of Representative, make one attempt to contact the taxpayer by telephone for the missing information. Document the contact or attempt (if the contact was unsuccessful) on the form using local phone call guidelines.
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For International Processing, if the POA is invalid or the representative cannot be reached, make one attempt to contact the taxpayer by telephone for the missing information. Document the contact or attempt (if the contact was unsuccessful) on the form using local phone call guidelines.
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CAF employees may solicit the third party for corrective action(s) by telephone and/or by fax. Use the following guidelines to contact the third party when any of the following information listed below is missing:
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Missing third party dated signature - includes prints from e-services Disclosure Authorization.
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Process each representative as a separate transaction. If information is missing for one representative, timely process all other representatives listed prior to rejecting with Letter 861C, Power of Attorney (Form 2848, Power of Attorney and Declaration of Representative) Incomplete for Processing, or other applicable correspondence. Indicate processed next to the representative input to the system.
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Missing designation.
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Form 706, U.S. Estate Tax Return, decedent date of death missing
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Third party attempting to act outside authority granted, e.g., redelegation or substitution.
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Authorization indicates retaining third parties from earlier authorization but copy of original authorization not attached.
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If the Form 2848, Power of Attorney and Declaration of Representative, or Form 8821, Tax Information Authorization, is valid but unprocessable, make one attempt to contact the representative by telephone for missing or incomplete information that can be obtained verbally. Document the contact or attempt (if the contact was unsuccessful) on form using local phone call guidelines. Documentation should include: time of call, outcome of call (i.e. busy, no answer etc).
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If the telephone contact is unsuccessful or the missing or incomplete information cannot be obtained verbally, reject the form by fax or Letter 861C, Power of Attorney (Form 2848, Power of Attorney and Declaration of Representative) Incomplete for Processing.
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All employees must stamp each form or correspondence with TE IDRS number and date of closing action.
Note:
As a result of inventory received in bulk, an exception is given to Philadelphia International CAF.
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Annotating the SDLN is always required. If edits and/or research are not required beyond the SDLN, enter data directly onto the CAF. The SDLN is a thirteen-digit number entered in the top right margin of the authorization. The SDLN is constructed as follows:
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Digits 1 and 2 represent the purge year.
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Form 706, U.S. Estate Tax Return, requests: The purge year will be the last two digits of the year of the taxpayer's signature date plus 15 years. Add 15 years to the final two digits of the year in which the taxpayer signs. For example, if the taxpayer’s signature date is 1/1/2007, the purge year will be 22 (07+15=22).
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Current and prior tax year/period requests: The purge year will be the year of the IRS received date plus 7. For example, if the IRS received date is 3/26/2007, the purge year will be 14 (the received date year, 2007 + 7 =14).
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Future tax years/periods requests: The purge year will be the last two digits of the year of the latest future tax year/periods plus 7. For example, if the latest tax year is 2008, the purge year will be 15 (2008 + 7 = 15).
Note:
Only input up to 3 future years. For example, if the current calendar year is 2007, only input requests through 2010 (2007 + 3 = 2010).
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The control cycle is the next 4 digits. Use the current processing cycle date.
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Digits 7 and 8 represent the location code. See below for codes provided for receipts by mail or fax, OTIA receipts and DA receipts:
Campus Mail and Fax OTIA MAMC 49 61 or 72 OAMC 29 82 or 83 PMAC 28 25 -
Digits 9 and 10 represent the TE/GE area office code and are used in this field on authorizations for Employee Plans and Exempt Organization applications.
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Digits 11-13 represent the blocking series. Each examiner has a block of numbers when inputting authorizations to the CAF. When 100 documents are reached (Number 99) within the same purge year and same control cycle, the blocking series number must be changed. The serial number will begin again with "00" under the new blocking number.
Note:
Code the authorization once you have determined it is processable. (Coding will be determined by local management).
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Name Control (IMF) The first four digits of the IMF last name or (BMF) the first four digits of the business name, as it appears on the authorization, is the name control. If there is a question regarding the name control, use CC INOLE or ENMOD to verify.
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Third Party- The third party's city, state and zip code must be present. If the street address is not present:
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Research using CC RPINK and edit on form.
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If more than one address and you are unsure which address to use, contact the third party by phone or fax.
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If research and attempts at phone/fax contact do no identify or confirm the third party's address, return the authorization for clarification.
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Determine the third party designation and code to the left of the third party name. Below is a quick reference to designation level codes on POA's.
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A - Attorney in good standing
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B - Certified Public Accountant (CPA) in good standing
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C - Enrolled Agent
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D - Bona fide officer of the taxpayer's organization
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E - Full-time employee of the taxpayer
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F - Member of taxpayer's immediate family
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G - Enrolled actuary
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H - Unenrolled return preparer
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K - Student Attorney
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L - Student CPA
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If Form 2848, Line 5 is modified by granting the additional authority to sign tax returns enter "S" in the middle left margin. An "M" supersedes an "S" . Do not enter an "S" if the third party is an unenrolled return preparer. If a POA indicates an unenrolled return preparer with the authority to sign a tax return, the authorization, absent other issues, is for specific use and not recorded on the CAF.
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If Form 2848, Power of Attorney and Declaration of Representative, Line 5 is blank, code a U (unmodified) in the left margin next to Box 5.
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If Form 2848, Power of Attorney and Declaration of Representative, Line 5 is modified by granting the additional authority to sign tax returns code S in the left margin. Do not code an S if the third party is an unenrolled return preparer.
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If Form 2848, Power of Attorney and Declaration of Representative, Line 5 indicates other specific added or deleted acts, code an M (modified) in the left margin next to Box 5.
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If a Form 2848, Power of Attorney and Declaration of Representative, contains a combination of representatives with modified and unmodified authority, do not input as one document. Take the following actions:
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Photocopy the authorization.
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Input the representative information having modified authority, creating an SDLN for the original document.
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Input the representative information having the unmodified authority, using a second SDLN for the photocopy.
Note:
EXCEPTION: If the only unmodified representative on the form is a designation H, load the document as modified using one SDLN
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If the authorization specifies copies of notices should be sent to a third party, code an N to the left of the third party name and address. A module can carry only two N indicators.
Note:
Code the notice indicator N to the left of the first third party listed if the taxpayer does not designate a third party to receive copies of notices.
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If the taxpayer specifies a third party to receive refunds and initials Form 2848,Power of Attorney and Declaration of Representative, line 6, (typed initials are not acceptable), code R to the left of the third party's name. A module can carry only one R indicator.
Note:
Never input an R indicator for an unenrolled return preparer, a student attorney or student accountant.
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A modified power of attorney exists when the taxpayer grants additional authority or limits authority. The following section describes one of the most common forms of modification and which requires CAF special handling.
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If modified Form 2848, Power of Attorney and Declaration of Representative, is received attached to an unmodified Form 2848, Power of Attorney and Declaration of Representative, with the same signature date and box 8 is checked, process the modified Form 2848, Power of Attorney and Declaration of Representative. Otherwise, contact/reject for clarification. Exception: A copy of the original request is not required if the original was input through DA.
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The taxpayer, and only the taxpayer, can grant a recognized representative the additional authority to substitute or delegate authority. The notice of substitution or delegation must be signed by the representative appointed on the power of attorney. See 26 C.F.R. 601.505(b)(2)(i). Additionally, the notice of substitution must be submitted in accordance with the below requirements or be returned to the recognized representative.
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The notice must be submitted with a copy of the original POA reflecting the authority to delegate.
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The new representative must meet Circular 230 criteria.
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The notice must specify the new representative's name and mailing address.
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If there is more than one representative, the notice designation must be clear.
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If you receive a case and research shows a third party is suspended or disbarred on the CAF system, use the following instructions:
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Check the OPR website to verify if the third party is suspended or disbarred
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Click intranet explorer.
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On the home page click on the box titled "COMMISSIONER" (located on the right hand side).
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Click on "Office of Professional Responsibility (OPR)" located in the middle of the page under Deputy Commissioner for Services & Enforcement Organization.
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On the left side of the page, click on the first arrow under "Want to Find Out."
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Following prompts, type in information and then click "search" .
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If the representative is listed as suspended or disbarred on the website do the following:
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Do not input a Form 2848, Power of Attorney and Declaration of Representative, signed by a disbarred or suspended third party. Instead, give the document and a print of the CC CFINK screen to the team manager or lead.
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The CAF Team manager must initiate contact with OPR to advise of the actions taken, provide supporting documentation upon request, verify the status of the third party, and assist OPR in any further action. OPR may be contacted at 202–622-7098
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If the OPR states the third party is not disbarred or suspended, immediately remove the action or practice code from the third party’s CAF record and process the authorization.
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If the OPR states the third party is not disbarred or suspended, immediately remove the action or practice code from the third party’s CAF record and process the authorization.
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If the OPR verifies that the third party is still currently disbarred or suspended, do not process the authorization.
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Forward the original, unprocessed Form 2848, Power of Attorney and Declaration of Representative, to the OPR along with a memorandum explaining the situation, so the OPR can take the appropriate action.
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Return a copy of the unprocessed POA authorization to the representative using a Letter 1727C, Power of Attorney Representative Number, or other applicable correspondence. Suggested Letter 1727C, Power of Attorney Representative Number, paragraphs:"B,K,L,S" with the following open paragraph: "Our records indicate that you are currently under suspension/disbarment. Therefore, the enclosed authorization cannot be accepted. For further information please call the Office of Professional Responsibility 202-622-7098"
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Send a Letter 2673C, Representative Response, or other applicable correspondence to the taxpayer. Suggested paragraphs: "A (or) B, E, and P" . You do not need to send a copy of the Form 2848, Power of Attorney and Declaration of Representative, to the taxpayer.
Note:
Do not return an authorization to a third party for reasons of a "D" or "S" indicator without first confirming his/her status with OPR.
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A third party under suspension or disbarred is suspended or disbarred only from practice. This same third party is still able to have tax information authority if the taxpayer grants it in a Form 8821, Tax Information Authorization, verbally through an OTIA, or by marking the Third Party Designee box on a tax return.
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Form 2848, Power of Attorney and Declaration of Representative, is used to authorize an individual to represent a taxpayer before the IRS and authorize the IRS to release confidential tax information to an individual for the account matters(s) specified. Form 2848, Power of Attorney and Declaration of Representative, can only be granted to an individual. for information on Powers of Attorney see IRS Publication 947, Practice Before the IRS and Power of Attorney.
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Below are the six essential elements of a processable authorization. If an essential element is missing or incomplete, the authorization is invalid. Refer to procedures in IRM 21.3.7.9.3 , Rejecting Missing/Incomplete Authorizations. If essential elements 1-5 are not present, the document must be returned to the taxpay







