EA Exam Part 3 / Representation Before the IRS

Form 2848 vs Form 8821: who can represent a taxpayer, and who can only look

Both forms let someone other than the taxpayer deal with the IRS about tax information. Only Form 2848 lets that person act for the taxpayer. Part 3 of the EA exam tests the difference.

By Jordan AshbyUpdated October 13, 2026Official IRS sources below

Part 3Representation, Practices and Procedures

25 of 85questions in this domain

One decisionto practice before moving on

Side by side

The two forms compared

**Form 2848 and Form 8821 side by side**Summarized from the current IRS instructions for each form. Check the current form and instructions before filing.
Question	Form 2848	Form 8821
Official name	Power of Attorney and Declaration of Representative	Tax Information Authorization
Who can be named	An individual who is eligible to practice before the IRS, such as an attorney, CPA, or enrolled agent. Part II lists the eligible designations in items (a) through (r).	Any individual, corporation, firm, organization, or partnership the taxpayer designates.
Inspect or receive confidential tax information	Yes, for the matters and periods listed.	Yes, for the type of tax and the years or periods listed.
Represent, advocate, or sign agreements, consents, and waivers	Yes. The representative can generally perform the acts the taxpayer can perform for the listed matters, except acts the form or IRS guidance excludes.	No. The designee cannot speak on the taxpayer's behalf, advocate a position, execute waivers, consents, or closing agreements, or represent the taxpayer in any other manner.
Signature from the person named	Required. Each representative signs Part II, Declaration of Representative, and enters a designation.	No designee declaration. The taxpayer signs.
Effect on earlier authorizations	When recorded on the CAF, it generally revokes earlier powers of attorney recorded for the same matter unless you check line 6 and attach copies of those you want to keep.	Unless line 4 is checked, it automatically revokes all prior tax information authorizations on file unless you check line 5 and attach copies of those you want to keep.
Endorse or negotiate a refund check	No.	No.

Same mechanics

What the two forms have in common

Both forms list the tax matters, form numbers, and years or periods covered. You can list the current period, periods that have already ended, and future periods, but the IRS will not record on the CAF future periods that run more than 3 years past December 31 of the year it receives the form.

Both forms have a line 4 box for a specific use that the IRS does not record on the Centralized Authorization File (CAF). If you check it, you mail or fax the form to the IRS office handling that matter. Otherwise you can submit it online, by fax, or by mail using the Where To File Chart in the instructions.

Signatures follow the same rule. A form sent by mail or fax needs a handwritten signature. A form signed electronically can only be submitted online through the IRS submission page. The instructions also point tax professionals to Tax Pro Account for faster processing of certain authorizations.

How the forms are laid out

Line by line

Form 2848 Part I runs from line 1, taxpayer information, through line 2, representatives, line 3, acts authorized (description of matter, form number, and years or periods), line 4, specific use not recorded on the CAF, line 5a, additional acts authorized, line 5b, specific acts not authorized, line 6, retention or revocation of prior powers of attorney, and line 7, the taxpayer's signature. Part II is the Declaration of Representative.

Form 8821 is shorter: line 1, taxpayer information, line 2, designee, line 3, tax information, line 4, specific use not recorded on the CAF, line 5, retention or revocation of prior tax information authorizations, and line 6, the taxpayer's signature.

Points the exam can test

Details that separate the right answer

Filing a Form 2848 does not revoke a Form 8821 that is already in effect (Publication 947).
An enrolled agent named only on Form 8821 can receive information but cannot represent the taxpayer on the strength of that form.
An unenrolled return preparer who does not meet the limited representation requirements can still be authorized to inspect or request tax information on Form 8821, but that does not allow representation.
An 8821 designee cannot substitute another party as the designee. A 2848 representative cannot substitute or add a representative unless the taxpayer gives written permission or checks that box on line 5a.
When Form 8821 is used for a purpose other than resolving a tax matter with the IRS, such as income verification for a lender, the IRS must receive it within 120 days of the taxpayer's signature date.
To revoke either form without naming someone new, write "REVOKE" across the top of a copy, add a current signature and date, and send it to the IRS as the instructions describe.

Free practice

Try the questions on these forms

Each free question shows the correct answer, a short explanation, and the reference tested.

Make the distinction

What changes the answer?

Access to information is not authority to advocate, sign agreements, or practice before the IRS.

Work the facts

A tax-practice scenario

A lender needs transcripts while an EA must negotiate an examination issue. Select the authorization that matches each role.

How to approach it

Identify the taxpayer, entity, transaction, and tax period first. Write the controlling tests in order, apply only the relevant facts, and keep the reporting result separate from any planning recommendation.

Common exam trap

Do not take this shortcut.

Using Form 8821 because it is simpler even though representation is required.

PassFast study move

Turn the rule into recall.

Define the act needed first, then choose information access, representation, or another disclosure consent.

ExplainState the governing distinction without notes.
ApplyChange one fact in the scenario and predict the new result.
RetrieveAnswer an unseen question, then review every option.

Official source and scope

This lesson follows the current PSI content outline and uses the IRS reference below for the underlying tax or practice framework. Always confirm current forms, instructions, thresholds, and effective dates before advising a taxpayer.