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Ezel / IRS Rulings / 201922027
Chief Counsel Advice 201922027 Released May 31, 2019 Advice

Revenue agents should stop communicating under invalid powers of attorney

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This page covers one taxpayer's ruling from 2019, which can't be cited as precedent. Ezel answers your situation under the current Code and IRS guidance, with citations.

Currency note: this determination was released in 2019
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel addressed a disclosure question involving Forms 2848, which authorize representatives to act for taxpayers. The advice states that if the forms were invalid, the revenue agents should stop communicating with the individual who relied on them. A separate question about the validity of tax returns was referred to two branch chiefs for assistance. The short email does not provide the facts that made the powers of attorney potentially invalid or resolve the return-validity issue.

Ruling snapshot

  • Question: May revenue agents continue communicating with an individual if the Forms 2848 authorizing that person are invalid?
  • Outcome: No. Communication should stop if the authorizations are invalid.
  • Key authorities: IRC § 6103; Form 2848

Full text (IRS public release)

ID:        CCA_2019042416163443
UILC:      6103.00-00

Number: 201922027
Release Date: 5/31/2019
From:
Sent: Wednesday, April 24, 2019 4:16:34 PM
To:
Cc:
Bcc:
Subject: FW: poa/6103 questions


-------,
With respect to the disclosure issue, if the 2848s are invalid, then the RAs should not continue
to communicate with this individual. As for the validity of the returns, I am copying the branch
chiefs of PA branches 1 and 2 who should be able to assist with that issue.

Thank you.

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