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Special Enrollment Examination
Part 1SEE Part 1: Individuals✓Part 2SEE Part 2: BusinessesPart 3SEE Part 3: Representation, Practices and ProceduresAn examiner asks a client to sign Form 872 because the assessment statute is about to expire. What should the EA explain?
Form 872 is a consent to extend the time to assess tax. Taxpayers may refuse, limit the extension to certain issues or set a date, and the IRS must tell them of these rights (section 6501(c)(4)(B)). If they refuse, the IRS will usually issue a notice of deficiency based on the information it has, which preserves Tax Court rights but leaves less time to resolve issues. Source: IRC 6501(c)(4); Pub. 1035. Tax year: 2025 (law as of 31 Dec 2025).
Thinking a consent is mandatory or forfeits appeal rights.
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