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Form 8821 or Form 2848: which should you file first?

Short answer

Form 8821 lets anyone the taxpayer names receive their IRS information, but not act for them. Form 2848 lets a CPA, EA, or attorney receive information and represent the taxpayer. File 8821 first to review the record and quote a fee; file 2848 once the client engages you to represent them.

By the BestTaxSoftware.com editorial team. Updated . Prices checked on vendor sites that day.

How do the two forms compare?

Form 8821 and Form 2848 side by side
QuestionForm 8821Form 2848
What it grantsAccess to tax informationRepresentation plus information
Who can be namedAny individual or organizationIndividuals eligible to practice
Can you speak for the client?NoYes, within the listed matters
Can you sign agreements?NoCan sign certain documents if authorized
Good forPre-engagement review, monitoring, bookkeepersCollection, audit, appeals work

What details do practitioners get wrong?

  • Listing the wrong form number or periods, which limits what you can see
  • Leaving out civil penalty matters, which are listed separately
  • Forgetting that a new authorization can revoke earlier ones unless you indicate otherwise

Questions practitioners ask

Can I submit 8821 and 2848 online?
Yes, through the IRS Tax Pro Account or the online submission tool, with electronic signatures where the IRS allows them.
Is Form 8821 enough to pull transcripts?
Yes. It authorizes you to receive the information covered by the form, including transcripts through TDS.

Sources

  1. About Form 8821, Tax Information Authorization (IRS)
  2. About Form 2848, Power of Attorney and Declaration of Representative (IRS)
  3. Transcript Delivery System (TDS) (IRS)
  4. Publication 947, Practice Before the IRS and Power of Attorney (IRS)