Changing the person handling an IRS matter is a case-management task as well as an authorization task. The new representative needs the complete record and a clear account of deadlines, submissions and unresolved questions. A new authorization alone does not transfer all that knowledge.
Distinguish representation from information access
Form 2848 authorizes an eligible individual to represent a taxpayer within the matters and periods specified. Form 8821 authorizes access to specified tax information; it does not grant the same authority to advocate or represent the taxpayer. Choose the form based on the intended role, not simply which form is easier to complete.
The IRS resources and instructions also address the effect of new authorizations, retention of prior authorizations and revocation or withdrawal. Review those instructions for the existing and proposed authorizations before assuming everyone will continue receiving notices. A tax preparer’s prior access does not establish that the new lawyer has the necessary authority.
Create a handoff inventory
| Item | What the new representative needs |
|---|---|
| Notices | Complete copies, enclosures, received dates and stated deadlines |
| Returns and account records | Filed versions, amendments, acknowledgments and relevant transcripts |
| Submissions | The exact response sent, attachments and delivery evidence |
| Authorizations | Existing forms, covered matters/periods and intended changes |
| Open tasks | Outstanding requests, promised records and responsible person |
Keep submitted documents distinct from drafts. A proposed response in an email thread may look complete but never have reached the IRS. The new representative needs to know which version was actually sent and what evidence establishes receipt.
Assign responsibility for the transition
Make a deadline list that identifies the source notice, date, required action and person responsible. Confirm who monitors correspondence during the handoff. Do not assume that submitting a new power of attorney extends a response or court deadline, or that a processing delay transfers responsibility to the IRS.
Ask the outgoing representative for an indexed file and a factual summary of what remains unresolved. Avoid relying on a verbal statement that the case is “almost finished.” Identify any missing documents and request them promptly, while preserving the original correspondence history.
Check the scope of the engagement
The engagement and authorization should fit the matter the new representative will handle. An audit, collections case, Appeals protest and court proceeding can require different work and authority. Confirm the relevant taxes, years and tasks rather than assuming an open-ended relationship from a general consultation.
Representation does not create blanket confidentiality for every preexisting record or every communication with a tax preparer. Discuss privilege questions with counsel using the actual facts. Do not relabel ordinary accounting records or assume adding a lawyer to a thread changes the status of earlier material.
Verify the file after the switch
Retain the signed forms and submission evidence. Check how future correspondence will be routed and preserve notices that continue arriving at old addresses or through an earlier representative. If an authorization is rejected or incomplete, resolve the specific issue and record the correction.
A useful completion checklist asks: does the new representative have the filed record, understand the deadlines, know the outstanding requests and possess the intended authorization? If any answer is uncertain, the handoff still needs work even if a form has been signed.
See our IRS audit representation page for matters involving an examination. Bring the current notices and existing authorizations to a consultation so the transition can be scoped accurately.
Primary sources
IRS Form 2848 resource and instructions; IRS Form 8821 resource and instructions. Source checked October 1, 2026. General information only.
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Samuel Landis, Esq.
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Sam Landis is a Beverly Hills IRS tax attorney specializing in IRS collection defense, audit representation, and international tax compliance for foreign nationals and US expats.