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CBA Tax Section Federal Business Tax Report

Written By:

Published On: January 18, 2018

There have been reported several incidents of practitioners being surprised by the new third party authentication procedure adopted by the IRS in October of 2017, effective January 3, and published in the IRM today at Section 21.1.3.3.

In response to several security compromises, IRS has revised its authentication process for third parties who contact the IRS on behalf of a taxpayer.

The former process included the requirement at the IRS ask for the taxpayer’s name and TIN and also the representative’s name and CAF number.

The new procedure, in addition to requesting the taxpayer’s name and TIN, calls for the agent to request the representative’s:

  1. Name
  2. CAF Number
  3. Social Security Number
  4. Date of Birth

Some practitioners are reporting that the new procedure is not being uniformly applied, and authentication requests for information such as the names, Social Security numbers and dates of birth of the representative’s children are being made, presumably to cross check that information with the representatives own tax returns.

The practitioner should have on file a current Form 2848 for the taxpayer that covers the tax periods and tax forms in question. Note that IRS will not accept versions of Form 2848 from before the October 2011 version. While the IRS will still provide assistance to third party representatives who file Forms 2848 from before October of 2011, the older form cannot be loaded into CAF.

Representatives of taxpayers using Form 8821, Tax Information Authorization, will, apparently, be subject to the same authentication requirements. Recall that Form 8821 does not empower the designee to represent the taxpayer before the IRS.