Did you know that with a valid POA you can represent your client at all levels of the IRS? This includes the chief counsel’s office. Once the case is in front of tax court, you are out of luck unless you are an attorney.
I find dealing with the Chief Counsels Office easier than dealing with appeals. The attorneys at this office are really ready to deal as they do not want to take up the courts time on something that can be settled.
Even though the POA can allow you to sign 433 A, B, 656, extension of the statute of limitation excreta, DO NOT SIGN. Have your client sign for your ultimate protection.
Things that the POA does not generally allow you to do in the way of representation can be added to line 5 of the authorization.
Form 8821 authorizes any member of your firm to request a FOIA, ROA and income data. The 8821 can be a request for multiple years, thereby getting the information you need to see the full picture of the status of the client, but not allow you to speak to the IRS for the years the information was requested.
When you are representing your client for a specific year, the POA should be for only that year. That way the IRS cannot ask you for information regarding other years and you can deal with the year at hand.
FYI – Currently there is a bottle neck at the POA department. It is taking up to six weeks to get your POA on the system. The IRS says that it is working to fix this.
Don’t forget to revoke your POA once you completed your case. This is easy, all you need to do is send a revoke letter with a copy of the original POA.
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