EA Part 3 Power of Attorney: Form 2848, CAF Numbers, and Representation Rules

Why Form 2848 Matters

An enrolled agent's right to practice before the IRS is only as useful as their authority to act on a client's behalf. Form 2848 (Power of Attorney and Declaration of Representative) is the mechanism that grants that authority. Without a valid Form 2848 on file, the IRS cannot discuss a client's account with the practitioner, regardless of the EA's credentials.

For Part 3, Form 2848 is tested for its requirements, limitations, scope, and revocation — as well as the important distinctions between Form 2848 and Form 8821.

Form 2848: Required Information

A properly completed Form 2848 must include:

Part I — Power of Attorney

• Taxpayer information: Name, address, taxpayer identification number (SSN or EIN), and daytime phone number
• Representative information: Name, address, and CAF (Centralized Authorization File) number, if assigned; also the designation (EA, CPA, attorney, etc.) and bar number or enrollment card number
• Tax matters: The specific tax form numbers (e.g., Form 1040, Form 941) and tax years or periods covered. A Form 2848 must specify the tax type and years — a blank authorization for "all matters" is not valid.
• Specific acts authorized or retained: The IRS presumes authority for standard acts of representation, but specific acts such as receiving refund checks, substituting or adding representatives, or signing tax returns must be explicitly authorized.
• Retention of taxpayer rights: By default, both the taxpayer and the representative receive copies of IRS notices. The taxpayer can elect to have notices sent only to the representative.

Part II — Declaration of Representative

The representative must sign and date a declaration confirming their authorization to practice before the IRS and that they are not currently suspended or disbarred.

The CAF System

The Centralized Authorization File (CAF) is the IRS's centralized database of third-party authorizations. When a Form 2848 is submitted for the first time, the IRS assigns the representative a unique CAF number. This number identifies the practitioner in the IRS system and allows IRS employees to quickly verify the practitioner's authorization when they call or correspond on a client's behalf.

A new representative should enter "NONE" in the CAF number field on their first submission; the IRS will assign a number. Once assigned, the same CAF number is used for all subsequent filings with all IRS offices.

The CAF system stores:

• The representative's name, address, and phone
• The scope of authorization (tax types and years)
• Any limitations or restrictions on authority

Acts Authorized vs. Acts That Require Explicit Authorization

By default, a Form 2848 grants the representative authority to:

• Receive and inspect confidential tax information
• Represent the taxpayer at conferences, hearings, and meetings
• Sign consents extending the statute of limitations (if explicitly authorized)
• Sign waivers agreeing to a tax assessment or collection action

Certain acts require explicit written authorization on the Form 2848:

• Receiving a refund check on behalf of the taxpayer
• Substituting or adding a new representative under the same authorization
• Signing a return on behalf of the taxpayer (only permitted in specific circumstances, such as disease or injury, continuous absence from the U.S. of at least 60 days, or specific permission from the IRS)
• Delegating authority to another individual

Form 8821: Tax Information Authorization

Form 8821 (Tax Information Authorization) is frequently tested alongside Form 2848 because they are often confused.

Form 8821 authorizes a designee to inspect and/or receive confidential tax information — but grants no right to represent the taxpayer before the IRS. A person authorized under Form 8821 cannot speak on the taxpayer's behalf, sign documents, or take any action other than receiving information.

Feature	Form 2848	Form 8821
Can receive tax information	Yes	Yes
Can represent taxpayer	Yes	No
Can sign documents	If authorized	No
Appears in CAF system	Yes	Yes
Can be used by non-practitioners	No	Yes

Form 8821 is useful when a taxpayer wants to authorize a financial institution, a mortgage lender, or an accountant who is not a credentialed practitioner to receive tax transcripts.

Substitute Power of Attorney

Circular 230 permits the use of a substitute power of attorney — a non-IRS form that contains substantially the same information as Form 2848. However, the IRS may not recognize or process substitute POAs that do not meet the required content standards. In practice, practitioners use Form 2848 for all IRS matters to avoid processing delays.

Unenrolled Return Preparer Rights

A paid return preparer who is not an EA, CPA, or attorney has limited representation rights under IRC Section 7526:

• They may represent clients only in examination of returns they prepared and signed
• They cannot represent clients before the IRS Office of Appeals, in collection matters, or before IRS counsel
• They must register and obtain a PTIN (Preparer Tax Identification Number)
• They must complete Annual Filing Season Program (AFSP) requirements to maintain even these limited rights

This is a frequently tested distinction: enrolled agents have unlimited representation rights before any IRS office for any tax matter; unenrolled preparers have limited examination-only rights tied to returns they prepared.

Revoking or Withdrawing a Power of Attorney

Revocation by the Taxpayer

A taxpayer may revoke a Form 2848 at any time by:

• Filing a new Form 2848 that revokes the prior authorization
• Sending a written notice of revocation to the IRS that identifies the taxpayer, the representative, the tax matters, and the effective date of revocation

Withdrawal by the Representative

A representative who wants to terminate their representation must:

• Send written notice to the taxpayer and to each IRS office where the Form 2848 was filed
• Specify the tax matters being withdrawn from

A representative cannot simply stop responding to IRS notices — formal withdrawal protects both the practitioner and the client by creating a clear record of when representation ended.

Automatic Revocation

A Form 2848 is automatically revoked when a new Form 2848 is filed for the same tax matters — unless the new form expressly states that the prior representative(s) are not being revoked.

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