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IRS e-services for Tax Professionals - Access Issues

Any tax professionals here who log-in to the IRS website to jeffm11/18/18
Two possibilities that I can think of off hand. First, it larrywilliams11/18/18
Thanks for the info. I have not filed a Form 2848. Is ther jeffm11/18/18
For those here who are not tax practitioners, some backgroun larrywilliams11/18/18
Dear jeffm: Yeah, you're going to need a Form 2848 for ea larrywilliams11/18/18
Here's a link to the instructions for Form 2848: https:// larrywilliams11/18/18
Thanks, Larry. Your posts have been very helpful. Wh jeffm11/18/18
If you want to see a reconstruction of a tax return (availab larrywilliams11/18/18
Jeff -- No, when you log in, there should be a page that all larrywilliams11/18/18
Thanks so much. This is the type of information I needed. jeffm11/18/18
You're welcome. Sounds like the administrator of the esta larrywilliams11/18/18
Jeff, since you're going to be preparing Federal return, you larrywilliams11/18/18
To digress a bit: I read this forum virtually every day, but larrywilliams11/18/18
what have you found more profitable, the CPA or JD? or is it whiteguyinchina11/19/18
Are you still a fellow Houstonian? jeffm11/19/18
Yes, I'm in the Houston area. Regarding the question by w larrywilliams11/19/18
Larry, The instructions say, "The time needed to comp jeffm11/19/18
Yeah, reading the full instruction booklet for the first tim larrywilliams11/19/18
Thanks. I hope you stay around for a while. You've been ve jeffm11/19/18
You're welcome. larrywilliams11/19/18
jeffm (Nov 18, 2018 - 8:03 pm)

Any tax professionals here who log-in to the IRS website to get transcripts on their clients?

I just signed up for the service, and when I try to connect to Transcript Delivery Services (TDS), it says I have not met the requirements to submit requests and should check out the tutorial.

There is no link to the tutorial. I don't know where it is. I also don't know why I don't qualify to submit requests.

It does authenticate my credentials, though. So, I doubt this is a user name/password issue.

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larrywilliams (Nov 18, 2018 - 9:20 pm)

Two possibilities that I can think of off hand.

First, it's the weekend, and the system might be undergoing routine maintenance, so that the problem is disguising itself as saying you "don't qualify to submit requests" when in fact you really do.

Second, in order to be able to access a transcript, you have to have a Form 2848, Power of Attorney and Declaration of Representative, on file with the Centralized Authorization File (CAF) unit of the Internal Revenue Service. There is fax number (and I don't have it in front of me at the moment) to fax a signed Form 2848 to the CAF unit. If you sent the Form 2848 only a few days ago, it's possible that it is just not posted to the system yet. I can't recall how long it takes for a Form 2848 to post to CAF, and a support person in my office normally takes care of that.

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jeffm (Nov 18, 2018 - 9:25 pm)

Thanks for the info. I have not filed a Form 2848. Is there no way to submit one online?

I thought maybe it would let me into the system and that the Form 2848 requirement would not apply until I entered information on the taxpayer whose transcript I want.

I have never been into this system before and don't know what to expect.

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larrywilliams (Nov 18, 2018 - 9:25 pm)

For those here who are not tax practitioners, some background: A client signs a Form 2848 that shows exactly which tax matters and tax periods the tax practitioner is authorized on. (The practitioner also signs the form.) With a few exceptions, the only persons authorized to represent taxpayers in dealings with the Internal Revenue Service are (1) attorneys, (2) certified public accountants, and (3) enrolled agents.

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larrywilliams (Nov 18, 2018 - 9:31 pm)

Dear jeffm:

Yeah, you're going to need a Form 2848 for each and every client for whom you want to obtain information.

We generally fax the Form 2848. I'm not sure that there is a way to send it online. And, as I noted above, I'm not sure how long it takes to have the 2848 be posted to the CAF system.

There is another approach, though. If you have a signed 2848, you can call the IRS Practitioner Priority Service, at (866) 860-4259. Tell the IRS employee who answers the phone that you have a new 2848 that is not "on CAF", and the IRS employee will let you fax the 2848 to him/her. The IRS employee will give you a phone number for a fax machine located a few feet from where the employee sits. After the employee receives your fax and asks you some PERSONAL questions, including your Social Security Number, CAF number, date of birth, etc., you can ask the IRS employee to fax you the transcript you desire. Typically, you'll receive the fax within a few hours.

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larrywilliams (Nov 18, 2018 - 9:35 pm)

Here's a link to the instructions for Form 2848:

https://www.irs.gov/pub/irs-pdf/i2848.pdf

Here's a link to the form itself:

https://www.irs.gov/pub/irs-pdf/f2848.pdf

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jeffm (Nov 18, 2018 - 9:37 pm)

Thanks, Larry. Your posts have been very helpful.


When you first log in to the TDS, what appears? Is it a list of all clients who've provided 2848's to you?

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larrywilliams (Nov 18, 2018 - 9:40 pm)

If you want to see a reconstruction of a tax return (available only for the three most recent years), you can ask for a "tax return transcript". It's not going to look like the actual tax return form, though.

If you want to see the account (debits and credits), you ask for an "account transcript". This shows the debits (such as assessments of tax, penalty and interest) and the credits (such as withholdings and other payments made), and the current net balance due (or net overpayment, if a credit balance).

The dates on the account transcript entries are confusing, because often those dates do not represent the actual data on which the entry was made or the described event occurred. It takes some study and experience to be able to decipher the account transcript.

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larrywilliams (Nov 18, 2018 - 9:47 pm)

Jeff -- No, when you log in, there should be a page that allows you to input the name, taxpayer ID number (usually a social security number in the case of an individual or an employer identification number in the case of a corporation, partnership, estate or trust) and the type of tax and tax period.

It's a clunky system in some ways, but once you get the hang of it, it usually works.

When you first sign in, you have to input your "CAF" number. If you don't have one yet, you will be assigned one after you file your first Form 2848 with the CAF unit.

A CAF number is generally in this format (just to make up a CAF number for illustration):

1111-11111R

All the characters are numerals except the last, which (as far as I know) is always the letter "R", for some reason.

However, when you use your CAF number to access the Transcript Delivery System, you would type it this way:

111111111

(without the dash, and without the letter "R").

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jeffm (Nov 18, 2018 - 9:58 pm)

Thanks so much. This is the type of information I needed.

I have to file tax returns for a few years where a decedent failed to do so. I represent the administrator of the estate.

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larrywilliams (Nov 18, 2018 - 10:19 pm)

You're welcome.

Sounds like the administrator of the estate needs to sign the 2848, in the middle of page 2. Then, you sign at the bottom of page 2.

Check out the instructions for Form 2848 for all the details. I think you should fax the 2848 to the CAF unit first, so you can get a CAF number assigned to you. Check the instructions, but I think you may need something from the Court showing that the administrator of the estate is duly appointed.

In addition to the CAF number, the Form 2848 asks for a "PTIN" (preparer tax identification number). If you are an attorney but you don't prepare Federal tax returns, I think maybe you don't need to get a PTIN assigned to you, but I'm not sure. (I am both an attorney and a CPA, and I've had both a CAF number and a PTIN for years.)

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larrywilliams (Nov 18, 2018 - 10:23 pm)

Jeff, since you're going to be preparing Federal return, you will need the PTIN as well.

See:

https://www.irs.gov/tax-professionals/ptin-requirements-for-tax-return-preparers

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larrywilliams (Nov 18, 2018 - 11:13 pm)

To digress a bit: I read this forum virtually every day, but I seldom post. The problem of too many lawyers chasing too few jobs -- which is what much of the discussion here is about -- is nothing new. I graduated from law school in the late 1980s, and it was really, really bad -- even back then. I completely understand how much worse it is now, after so many years. There are simply TOO MANY LAW SCHOOLS in this country. This has been the case since at least the 1980s.

Prior to law school, I had a tax background -- as a CPA. Over five years in public accounting prior to law school, and I saw some complex tax matters.

I graduated somewhere in the middle of my law school class (University of Houston, which in the late 1980s was ranked above SMU and Baylor, second only to UT Austin among the Texas law schools).

In the late 1980s, large firms and recruiters wanted to know only two things: Were you in the top 10 percent of your law school class, and were you on law review (“no” to both questions, in my case). One recruiter told me, point blank: For a tax law position, Big Law does not care WHAT the quality and extent of your tax experience is. It’s grades and law review. Period.

So, for the past 28 years or so, I have instead had a specialized tax practice -- ostensibly, as a CPA, but with a heavy emphasis on original tax research, on representing clients in dealings with the Internal Revenue Service, in drafting exotic tax return disclosure statements, and advising other attorneys on tax matters, assisting them in drafting pleadings in a few cases -- and a little pro bono work in the U.S. Tax Court.

Last Friday, I finished a project that involved turning an asserted Federal income tax liability of over $1.8 million (including interest and penalties) into a refund of over $1.5 million of tax and interest. I solve real problems. I have found Federal tax to be a fascinating and energizing practice, and the odd specialty I have -- which involves an interplay with areas of law not usually associated with a tax practice -- has given me the opportunity to help people. I have never gotten tired or burned out.

When I graduated from law school, I wanted Big Law. I didn’t get it. That may have been a blessing in disguise. I quickly found something that I really enjoy. Sometimes, what you believe is bad fortune turns out to be the turn in the road that takes you to a place you had no idea existed, and it turns out to be just the place you needed to be.

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whiteguyinchina (Nov 19, 2018 - 1:54 am)

what have you found more profitable, the CPA or JD? or is it the combo?

thanks for sharing your story.

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jeffm (Nov 19, 2018 - 8:13 am)

Are you still a fellow Houstonian?

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larrywilliams (Nov 19, 2018 - 9:14 am)

Yes, I'm in the Houston area.

Regarding the question by whiteguyinchina, I would say it's the combination of the two backgrounds. I couldn't do exactly what I do without both.

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jeffm (Nov 19, 2018 - 9:27 am)

Larry,

The instructions say,

"The time needed to complete and file Form 2848 will vary depending on individual circumstances. The estimated average time is: Recordkeeping, 11 min.; Learning about the law or the form, 53 min.; Preparing the form, 77 min.; Copying and sending the form to the IRS, 58 min."

I am not understanding this. It shouldn't take 58 minutes to copy and send the form. Are they suggesting this 53 minutes in in addition to preparing (77 minutes) for a total of 130 minutes? Likewise, is learning (53 minutes) in addition to preparing (77 minutes)? I doubt these figures are added, but I want to know how the IRS estimates work.

Thanks.

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larrywilliams (Nov 19, 2018 - 11:41 am)

Yeah, reading the full instruction booklet for the first time could be about an hour, but filling in the form doesn't normally take 77 minutes. I don't know how the IRS comes up with the time estimates (and I never pay attention to them).

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jeffm (Nov 19, 2018 - 11:52 am)

Thanks. I hope you stay around for a while. You've been very helpful!

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larrywilliams (Nov 19, 2018 - 10:22 pm)

You're welcome.

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