F2848_Sup Stmnt

F2848_Sup Stmnt.doc

Power of Attorney and Declaration of Representative

OMB: 1545-0150

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SUPPORTING STATEMENT

(Form 2848, Form 2848(SP)



  1. CIRCUMSTANCES NECESSITATING COLLECTION OF INFORMATION


26 CFR 601, Subpart E, Conference and Practice Requirements, sets forth the rules for acting on behalf of a taxpayer, presenting written or oral statements of fact on behalf of the taxpayer, and receiving or inspecting confidential tax information concerning the taxpayer being represented.


Form 2848 allows a representative to perform any and all acts that the taxpayer may perform with the exception of endorsing refund checks. Tax returns may be signed by a representative for the taxpayer in limited situations.


2. USE OF DATA

The form is used by the IRS to identify representatives of a taxpayer and to record any limitations on the representative’s right to represent the taxpayers. Unless the proper form is on file, the representative will not be recognized by the IRS and confidential information cannot be disclosed.


3. USE OF IMPROVED INFORMATION TECHNOLOGY TO REDUCE BURDEN


We are currently offering electronic filing on Form 2848.


  1. EFFORTS TO IDENTIFY DUPLICATION


We have attempted to eliminate duplication within the agency wherever possible.

5. METHODS TO MINIMIZE BURDEN ON SMALL BUSINESSES OR OTHER SMALL ENTITIES


Not applicable.


  1. CONSEQUENCES OF LESS FREQUENT COLLECTION ON FEDERAL PROGRAMS OR POLICY ACTIVITIES


Not applicable.


7. SPECIAL CIRCUMSTANCES REQUIRING DATA COLLECTION TO BE INCONSISTENT WITH GUIDELINES IN 5 CFR 1320.5(d)(2)


Not applicable.


  1. CONSULTATION WITH INDIVIDUALS OUTSIDE OF THE AGENCY ON AVAILABILITY OF DATA, FREQUENCY OF COLLECTION, CLARITY OF INSTRUCTIONS AND FORMS, AND DATA ELEMENTS


Periodic meetings are held between IRS personnel and representatives of the American Bar Association, the National Society of Public Accountants, the American Institute of Certified Public Accountants, and other professional groups to discuss tax law and forms. During these meetings, there is an opportunity to make comments regarding Form 2848.


In response to the Federal Register Notice dated August 30, 2010, (75 FR 53021), we received no comments regarding Form 2848.

9. EXPLANATION OF DECISION TO PROVIDE ANY PAYMENT OR GIFT TO RESPONDENTS


Not applicable.


  1. ASSURANCE OF CONFIDENTIALITY OF RESPONSES


Generally, tax returns and tax return information are confidential as required by 26 USC 6103.


11. JUSTIFICATION OF SENSITIVE QUESTIONS


Not applicable.


12. ESTIMATED BURDEN OF INFORMATION COLLECTION


The burden estimate is as follows:


Number of Time per Total

Responses Response Hours


Form 2848(paper) 358,333 1.66 594,833

 Form 2848(on line)  100,000 1.61 161,000

Form 2848(SP) 80,000 2.26 180,800

538,333 936,633


Estimates of the annualized cost to respondents for the hour burdens shown are not available at this time.


The following regulations impose no additional burden. Please continue to assign OMB number 1545-0150 to these regulations.

601.501 through 601.509

601.514



We have reviewed the above regulations and have determined that the reporting requirements contained in them are entirely reflected on the form. The justification appearing in item 1 of the supporting statement applies both to the regulations and to the form.


13. ESTIMATED TOTAL ANNUAL COST BURDEN TO RESPONDENTS


As suggested by OMB, our Federal Register Notice dated Federal Register Notice dated August 30, 2010, (75 FR 53021), requested public comments on estimates of cost burden that are not captured in the estimates of burden hours, i.e., estimates of capital or start-up costs and costs of operation, maintenance, and purchase of services to provide information. However, we did not receive any response from taxpayers on this subject. As a result, estimates of the cost burdens are not available at this time.


14. ESTIMATED ANNUALIZED COST TO THE FEDERAL GOVERNMENT


After consultation with various functions within the Service, we have determined that the cost of developing, printing, processing, distribution, and overhead for Form 2848 is $816,924.


  1. REASONS FOR CHANGE IN BURDEN


The increase in burden in this renewal occurred in order to rectify a discrepancy in the burden computation which was utilized in the prior submission.


16. PLANS FOR TABULATION, STATISTICAL ANALYSIS AND PUBLICATION


Not applicable.


  1. REASONS WHY DISPLAYING THE OMB EXPIRATION DATE IS INAPPROPRIATE


See attachment.


  1. EXCEPTIONS TO THE CERTIFICATION STATEMENT ON OMB FORM 83-I


Not applicable.


Note: The following paragraph applies to all of the collections of information in this submission:

An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the collection of information displays a valid OMB control number. Books or records relating to a collection of information must be retained as long as their contents may become material in the administration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by 26 U.S.C. 6103.


OMB EXPIRATION DATE


We believe the public interest will be better served by not printing an expiration date on the form(s) in this package.


Printing the expiration date on the form will result in increased costs because of the need to replace inventories that become obsolete by passage of the expiration date each time OMB approval is renewed. Without printing the expiration date, supplies of the form could continue to be used.


The time period during which the current edition of the form(s) in this package will continue to be usable cannot be predicted. It could easily span several cycles of review and OMB clearance renewal. In addition, usage fluctuates unpredictably. This makes it necessary to maintain a substantial inventory of forms in the supply line at all times. This includes supplied owned by both the Government and the public. Reprinting of the form cannot be reliably scheduled to coincide with an OMB approval expiration date. This form may be privately printed by users at their own expense. Some businesses print complex and expensive marginally punched continuous versions, their expense, for use in their computers. The form may be printed by commercial printers and stocked for sale. In such cases, printing the expiration date on the form could result in extra costs to the users.


Not printing the expiration date on the form(s) will also avoid confusion among taxpayers who may have identical forms with different expiration dates in their possession.


For the above reasons we request authorization to omit printing the expiration date on the form(s) in this package.


File Typeapplication/msword
File TitleSUPPORTING STATEMENT
Last Modified ByJNMNB
File Modified2011-02-07
File Created2007-07-23

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