Federal Tax

Practice Before the IRS; Attorney’s Fees Tax Proceedings (Portfolio 620)

  • This Portfolio discusses the practice regulations in Circular No. 230 with a focus on the rules governing practice before the IRS by attorneys, CPAs, and enrolled agents and actuaries.

Description

Bloomberg Tax Portfolio, Practice Before the IRS; Attorney’s Fees in Tax Proceedings, No. 620, discusses the practice regulations in Circular No. 230 with a special focus on the rules governing practice before the IRS by attorneys, certified public accountants, enrolled agents, and enrolled actuaries.

Also discussed are power of attorney and tax information authorization filing requirements, which are imposed on all categories of representatives with respect to practice before the IRS. Circular No. 230 also prescribes rules for the issuance of tax opinions, disciplinary proceedings for violations of Circular No. 230, and disciplinary hearings before Administrative Law Judges.

While focusing on the practice rules for attorneys and CPAs, this Portfolio also considers the requirements for practice before the IRS by non-attorneys and non-CPAs. The enrollment procedures for qualifying to practice, the procedures for establishing technical competency by written examination, and the steps in applying for enrollment are all discussed. In addition, this Portfolio considers limited practice before the IRS as well as statutory and regulatory prohibitions relating to representation before the IRS by former government officers and employees.
Also discussed are ยง7430 and the requirements for attorney’s fees and other costs involved in an IRS administrative or court proceeding.

This Portfolio may be cited as Dennehy, Ehrlich and Dennehy, 620 T.M., Practice Before the IRS; Attorney’s Fees in Tax Proceedings.

Table of Contents

Part I: Practice Before the IRS
1:I. Introduction
1:II. Practice Regulations
1:III. Practice Before the IRS
1:IV. Authorization to Practice
1:V. Application, Renewal and Continuing Education Process
1:VI. Limited Practice Without Enrollment
1:VII. Taxpayer Consent to Disclose or Use Tax Return Information
1:VIII. Powers of Attorney and Tax Information Authorizations
1:IX. Certain Prohibited or Restricted Representation
1:X. Practice Duties and Restrictions
1:XI. Disciplinary Proceedings

Part II: Attorney’s Fees in Tax Proceedings
2:I. Introduction
2:II. Requirements of Section 7430
2.III. Limitations on Awards
2.IV. Recoverable Fees and Costs
2.V. Procedures for Recovery of Costs and Fees
2.VI. Recovery of Fees Under Other Statutes

Edward K. Dennehy
Edward K. Dennehy
Partner, Tax
KPMG LLP
Steve-Ehrlich
Stephen Ehrlich
Principal, Tax
KPMG LLP
Annmarie Dennehy
Annmarie Dennehy
Manager, Tax
KPMG LLP
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