ITIN›Acceptance Agents’ Guide for Individual Taxpayer Identification Number
Exhibit J Infractions and Sanctions
0125 Publ 4520 (PDF) · 2026-10-03 edition · updated 2026-10-04 · United States
| Type of Infraction | Defni ition | Examples | Action/ |
|---|---|---|---|
| None | No fnding cited during Compliance review. |
N/A | Acceptance Letter |
| Minor Note: Multiple occurrences of any type of infraction can impact the fnal action/ sanction imposed. |
Finding cited during Compliance review that does not impact the taxpayer’s ability to secure an ITIN. |
- No written Standard of Operation - Failure to notify client that IRS issued temporary TIN - Failure to notify IRS of change in location - Failure to explain the ITIN Process to applicant - Failure to provide applicant with an intake sheet - Failure to maintain copies of all IRS Notices - Failure to maintain copies of required documents in all client fles (i.e. Form W-7, COA, etc.) |
Warning Letter |
| Serious Note: Multiple occurrences of any type of infraction can impact the fnal action/ sanction imposed. |
Finding cited during Compliance review that impacts the taxpayer’s ability to secure an ITIN. |
- Information on Form W-7 (COA) not consistent with documents in the fles (multiple occurrences) - Invalid signature on Form W-7 (No Power of Attorney) - Failure to complete a Form W-7(COA) - Unauthorized party signed Form W-7 (COA) - Information on Form W-7 (COA) no consistent with documents in the fles (one occurrence) |
Probation Letter |
| Flagrant | Finding cited during Compliance review that adversely impacts the taxpayer’s ability to secure an ITIN, impedes the review of the organization and/ are egregious in nature (i.e. questionable) or willful non- compliance with CAA guidelines as established in Rev. Proc. 2006-10, Acceptance Agent Agreement, Publication 4520 |
- Failure to submit complete and accurate Forms W-7 (submit- ting copies of documents for dependents other than passports or birth certifcates) - Failure to maintain copies of required documents in all client fles (identifcation documentation or exception documentation) - Failure to complete or provide adequate training to employees - Failure to comply with document retention standards - Seasonal Operations - Accepting expired documentation - Failure to cooperate with Compliance review - Failure to respond to IRS, TIGTA, GAO inquiries |
Termination Letter |
50 Acceptance Agents Guide
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