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Tax Management Portfolio, Practice Before the IRS; Attorney's Fees in Tax Proceedings, No. 620-3rd, 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 §7430 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, 620-3rd T.M., Practice Before the IRS; Attorney's Fees in Tax Proceedings.
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