E-Filters Beware

27 Annual Tax Controversy Institute

The Beverly Hills Hotel
9641 Sunset Boulevard
Beverly Hills, California

October 25, 2011

©2011 Dennis Brager, Esq.*

Revocation of EFIN: Cause and Effect

Introduction: Despite the fact that revocation of a tax preparer’s EFIN can effectively eliminate his ability to earn a living there is very limited guidance from the IRS as to when an EFIN will be revoked. That guidance is set forth in Rev. Proc. 2007-40 and IRS Publication 3112 (3-09), and is extremely general. The review process for the revocation of an EFIN is shrouded in mystery, and appears to be subject to the whim of mysterious individuals within the IRS.

I. The IRS may sanction a Provider for the same reasons that it denies an application to participate in IRS e‑file. Before sanctioning, the IRS may issue a warning letter that describes specific corrective action the Provider must take. The IRS may also sanction a Provider without issuance of a warning letter.

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*Dennis Brager, Esq., is a State Bar Certified Tax Specialist in Los Angeles. A former IRS senior trial attorney, Mr. Brager now devotes his efforts exclusively to helping clients resolve their tax problems with the IRS and California State tax agencies. Services include negotiating Tax Debts, Tax Fraud Representation, Tax Litigation, Tax Audit and Appeals Representation,  Tax Preparer Penalty Mitigation, Payroll Tax Audits, and California Sales Tax Problems. He may be reached at 800.380.TAX LITIGATOR.