IRS Enrolled Agent Part 3 Course Notes

This is the Circular 230 core. First identify WHO is acting, WHAT IRS matter is involved, and WHICH duty applies. Enrolled agents generally have unlimited practice rights before the IRS, but that does not make them attorneys or authorize practice in federal court. Client instructions never excuse a Circular 230 violation.

• Assuming EA status authorizes federal-court practice.

• WHO → FORUM → AUTHORITY before answering representation questions.

Representation starts with authority. Form 2848 authorizes an eligible representative to act for specified matters/periods; Form 8821 authorizes disclosure/receipt of tax information but NOT representation. After authority is established, build the case around the exact issue, deadline, evidence, and controlling authority.

• Using Form 8821 to represent a taxpayer.

• ACT/ADVOCATE = 2848; INFO ONLY = 8821.

Collection and Appeals questions are deadline questions disguised as tax questions. Identify the NOTICE, ACTION, DEADLINE, and RELIEF sought before choosing a procedure. For collections, compare ability to pay with full-pay/installment/OIC/CNC options. For examinations and Appeals, organize the case by disputed issue, facts, authority, evidence, and requested adjustment.

• Treating OIC as automatic debt reduction.

• Collection: Liability → Compliance → Financials → CSED → Alternative.

The filing section tests process control. Software does not shift responsibility away from the preparer. Verify the return, obtain valid authorization/signature, transmit timely, review the IRS acknowledgment, correct rejects, protect taxpayer data, and document any paper-filing exception.

• Assuming a transmitted return is filed even though IRS rejected it.

• PREPARE → REVIEW → AUTHORIZE → TRANSMIT → ACKNOWLEDGE → RESOLVE.