Ezel / IRS Rulings / 1333009
Chief Counsel Advice 1333009 Released August 16, 2013 Advice

CCA addresses who may sign a statute consent for taxpayers

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This page covers one taxpayer's ruling from 2013, 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 2013
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 addresses whether a person authorized under Form 2848 may sign a statute consent on Form 872 for taxpayers. The advice states that the power of attorney may do so if that person is authorized to sign Form 872 on the taxpayers' behalf. It gives an unenrolled preparer as an example of someone who is not authorized to sign the form.

Ruling snapshot

  • Question: When may a power of attorney sign Form 872 for taxpayers?
  • Outcome: Advice given. The person must be authorized to sign Form 872 on the taxpayers' behalf.
  • Key authorities: Form 2848; Form 872.

Full text (IRS public release)

ID: CCA_2013062517315038
Office: ------------
UILC: 9999.00-00
Number: 201333009
Release Date: 8/16/2013
From: ------------------------
Sent: Tuesday, June 25, 2013 5:31:52 PM
To: ------------------------
Cc:
Subject: FW: Form 2848 and statute consent (Form 872)

From: --------------------------
Sent: Tuesday, June 25, 2013 5:27 PM
To-------
Subject: RE: Form 2848 and statute consent (Form 872)

-----------is correct as long as the POA is someone who is authorized to sign the Form 872 on behalf of the
taxpayers (i.e, not an unenrolled preparer).

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