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Form 2848 - IRS rep asking for practitioner's SSN


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On a call with an IRS representative today, after I faxed over Form 2848, the representative asked me for my personal SSN in addition to my CAF number and my client's EIN.  When I expressed surprise, she indicated that it was a very new IRS procedure.  I'm curious - has this happened to anybody else?

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Here’s a link to a relevant section of the Internal Revenue Manual.

 

“This section is intended to provide uniform guidelines to employees who deal with representatives and/or who receive and inspect Form 2848, Power of Attorney and Declaration of Representative (POA), Form 8821, Tax Information Authorization (TIA), and similar documents.”

 

https://www.irs.gov/irm/part4/irm_04-011-055

 

But if there really is a recent procedure, it might not have been compiled in the Manual (or in the IRS website’s public display of it).

 

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

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As an ERPA I represented a client on recent (3Q/4Q 2017) 401(k) plan audit, sent in a 2848 co-executed with the client, but do not remember having to provide my SS# for any reason.

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

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I have tons of active POAs as an Enrolled Agent. None of them have my ss number on them. If this is a "recent procedure", simply ask the agent to provide a copy of any official document that says that is the new rule before you provide ss number.  Such a DRAMATIC change would have to be publicly announced before it could be implemented.

See my later post below with the reason IRS is now asking for additional info; looks like it is real!

Lawrence C. Starr, FLMI, CLU, CEBS, CPC, ChFC, EA, ATA, QPFC
President
Qualified Plan Consultants, Inc.
46 Daggett Drive
West Springfield, MA 01089
413-736-2066
larrystarr@qpc-inc.com

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According to the Journal of Accountancy:

"Although the new [Internal Revenue Manual] section is not yet available on the IRS’s website, its existence has been verified by IRS personnel.  The IRS says it plans to communicate the changes to practitioners in the near future."

 

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

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Here's the scoop:

 

    47f470e3-6587-4c34-92e8-2dcd77f93b25.jpg   
 
NAEA has received numerous inquiries from members on a new "policy" at IRS where IRS assistors serving the Practitioner Priority Service line have been asking members with powers of attorney on file for taxpayers to provide an unknown assortment of the following items for verification before the IRS assistor will help the practitioner with the power of attorney on file:
  • the practitioner's Social Security number (SSN);
  • the practitioner's date of birth;
  • CAF number;
  • the greatest source of income from the practitioner's last filed 1040;
  • the address and filing status from the practitioner's last filed 1040; and potentially,
  • the SSN of someone on the practitioner's last filed 1040 who is not the practitioner.
NAEA recently received a partner bulletin from IRS relaying the following message on this new procedural change:
 
The IRS continues to review its procedures to better protect sensitive taxpayer data. As part of this effort, the IRS will request additional information from tax professionals who contact us through the Practitioner Priority Service or any toll-free IRS telephone number.
 
This procedural change will require tax practitioners to provide personal information so that our customer service representatives may confirm their identities. This additional information may include data such as your Social Security number and your date of birth. This personal information, in addition to the CAF number, is necessary to verify the identities of the person to whom we are releasing taxpayer information.
 
We've also made an update to Form 2848, Power of Attorney, and Form 8821, Tax Information Authorization, that will require you to inform your client if you are using an Intermediate Service Provider to access client transcripts via the Transcript Delivery System. A box must be checked if you are using a third party. We define Intermediate Service Providers as privately owned companies that offer subscriptions to their software and/or services that the taxpayer's authorized representative can use to retrieve, store, and display tax return data (personal or business) instead of obtaining tax information directly from the IRS. The IRS must know who is using our tools; and taxpayers must know when a party other than their authorized representative is involved in accessing their sensitive data.
 
We realize there have been a number of changes for tax professionals in recent weeks. But each change is intended to enhance protections for you and your clients. Unfortunately, business as usual is no longer an option. Cybercriminals are well-funded, persistent and adept at stealing data from outside the IRS and using it to eventually file fraudulent tax returns. As cybercriminals evolve, so must we.
 
As part of our efforts, we also have strengthened protections for IRS e-Services. If you are an e-Services account holder, we urge you to immediately upgrade your account through our new two-factor identity verification process. Some of you may need to complete this process by mail which could add 10 days or more to the process. Please, do not wait until the start of filing season or until you have an urgent need for one of the e-Services tools before updating your account.
 
In the future, we will be asking each e-Service user to sign a new user agreement intended to ensure that all tax professionals understand their security obligations. We will share this information with you in advance.
 
Protecting you and your clients from identity theft is a paramount issue for us. But we can't do it alone. We need your help and your understanding as we continue to review and enhance our procedures.
 
NAEA will continue to update the membership on any new updates to this procedural change. Please also continue to monitor the IRS's Newsroom webpage for updates on this new policy.

Lawrence C. Starr, FLMI, CLU, CEBS, CPC, ChFC, EA, ATA, QPFC
President
Qualified Plan Consultants, Inc.
46 Daggett Drive
West Springfield, MA 01089
413-736-2066
larrystarr@qpc-inc.com

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1 hour ago, XTitan said:

I was so hoping to find some humor in this thread. 

The humor is it is 2018 and the government is just now getting to this kind of security with this kind of data.

I mean it is going to be just this year they are no longer going to print SSNs on people's Medicare cards!  In many states if you put a person's SSN on such a public form it would be a crime and has been so since the late '90s but the Feds are playing catch up! 

 

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