Ezel / IRS Rulings / 1129038
Chief Counsel Advice 1129038 Released July 22, 2011 Advice

CCA 1129038: Representatives may sign tax returns only under specified authorization rules

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This page covers one taxpayer's ruling from 2011, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2011
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 Advice addressed when a representative may sign a tax return or refund claim for a taxpayer. It stated that the act must be permitted under the Code and regulations and specifically authorized by a power of attorney on Form 2848. It also explained that the conditions in section 1.6012-1(a)(5) must be met before an agent may sign an income tax return, otherwise the revenue agent should ask the taxpayer to send signed returns.

Ruling snapshot

  • Question: Whether a representative may sign an income tax return or refund claim on a taxpayer's behalf.
  • Outcome: Advice given.
  • Key authorities: IRC § 6012; Treas. Reg. § 1.6012-1(a)(5); Conference and Practice Requirements § 601.504(a)(6).

Full text (IRS public release)

ID: CCA_2011063014301044 Number: 201129038
Release Date: 7/22/2011
Office: ----------------------------
UILC: 6012.00-00

From: ---------------------
Sent: Thursday, June 30, 2011 2:30:12 PM
To: ------------------
Cc: -----------------------
Subject: RE: Section 6012 Regulations Question

A representative is generally not authorized to sign a tax return or claim for refund on
behalf of a taxpayer unless the act is both (1) permitted under the Code and regulations
and (2) specifically authorized in the power of attorney (Form 2848). See Conference
and Practice Requirements § 601.504(a)(6). The conditions in section1.6012-1(a)(5)
must be met to have an agent sign an income tax return on behalf of a taxpayer(s). If
these conditions are not met, the revenue agent should request that the taxpayer send
in signed returns.

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