Can an AFSP preparer represent a client before the IRS?
Sometimes, but the rights are limited. AFSP participants may have limited representation rights for clients whose returns they prepared and signed, and only before specified IRS functions. Those rights are not the same as the broad representation rights of an enrolled agent, CPA, or attorney.
For exam purposes, ask:
- Did the preparer have AFSP status for the relevant year?
- Did the preparer prepare and sign the return at issue?
- Is the IRS function within the limited rights?
- Is the matter an audit-style issue rather than collection or appeals?
If any of those facts fail, do not assume AFSP representation authority exists.
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