CCA 1138044: An individual representative may substitute another representative on Form 2848

Plain-English summary

Chief Counsel Advice addressed whether a taxpayer can give a large firm the power to change the taxpayer's representative on Form 2848. The advice stated that a taxpayer may authorize an individual representative to substitute or add another representative by expressly including that authority on line 5 of Form 2848. The taxpayer cannot grant that authority to an entire firm. Only an authorized individual representative may submit a new Form 2848 naming a replacement representative, with a copy of the original form showing the authority.

Ruling snapshot

• Question: Can a taxpayer authorize an entire firm, rather than an individual representative, to substitute or add a representative on Form 2848?
• Outcome: advice given
• Key authorities: Form 2848, line 5

Full text (IRS public release)

ID: CCA_2011083007424950 Number: 201138044
Release Date: 9/23/2011
Office: -----
UILC: 9999.00-00

From: -----------------------
Sent: Tuesday, August 30, 2011 7:43:13 AM
To: ----------------------
Cc:
Subject: FW: Question regarding representation and delegation rights by large firms

The previous advice is still correct. A taxpayer may grant an individual representative
the power to substitute or add another representative by expressly including this
authority on line 5 of a Form 2848. The taxpayer, however, may not grant this authority
to an entire firm. Thus, only an authorized individual representative, not a firm, can
submit a new Form 2848 naming a new representative (by attaching a copy of the
original Form 2848 showing that the individual representative has the authority to do
so).

Please let me know if I can be of further assistance.