- Ledger Lowdown
- Posts
- When tax professionals lose their IRS privileges
When tax professionals lose their IRS privileges
Most tax enforcement stories focus on taxpayers. Less visible, but just as serious, are cases where tax professionals themselves lose the right to represent clients before the IRS.

What the IRS Office of Professional Responsibility does
The IRS Office of Professional Responsibility, commonly known as OPR, oversees the conduct of professionals who practice before the IRS. This includes CPAs, attorneys, and enrolled agents who prepare returns, handle audits, negotiate with collections, and represent taxpayers in disputes.
OPR enforces the standards set out in Circular 230. When a practitioner violates those rules or engages in misconduct, OPR can impose disciplinary sanctions that limit or completely remove the ability to practice before the IRS. Losing that privilege can effectively shut down a tax practice.
Types of disciplinary sanctions OPR can impose
OPR has several enforcement tools, depending on the seriousness of the misconduct and the practitioner’s disciplinary history.
Censure is a public reprimand that becomes part of the practitioner’s record. While the individual may still be allowed to practice, the reputational damage can be significant.
Suspension temporarily bars the practitioner from representing clients before the IRS for a defined period.
Disbarment removes the right to practice before the IRS for a long term or indefinite period. In many cases, reinstatement is not automatic and requires a formal application and proof of rehabilitation.
Many sanctions are listed as indefinite, meaning there is no preset end date and the burden is on the practitioner to seek reinstatement.
Recent OPR sanctions across multiple states
Recent disciplinary listings published by OPR show sanctions imposed on professionals across the country. These actions are also published in the Internal Revenue Bulletin, which serves as the official public record.
Recent examples include a CPA in California sanctioned indefinitely effective August 2025, an attorney in Colorado sanctioned indefinitely effective September 2024, and an enrolled agent in Iowa sanctioned indefinitely effective September 2025.
Each listing identifies the practitioner’s name, credential, location, and effective date, making it clear who is currently barred from practicing before the IRS.
Sanctions involving professionals with multiple credentials
Holding multiple credentials does not shield a practitioner from discipline. In fact, OPR sanctions apply to the individual’s right to practice before the IRS regardless of whether they are a CPA, attorney, enrolled agent, or some combination of the three.
Recent cases include CPAs who are also attorneys in Kansas and New Jersey, as well as CPAs in Tennessee and Virginia, all of whom received indefinite sanctions. These cases show that experience and credentials do not prevent discipline when professional standards are violated.
Reinstatement after IRS discipline
Not all OPR cases end permanently. Some practitioners are reinstated after meeting specific conditions and demonstrating that they are fit to resume practice.
One recent reinstatement involved a practitioner in California who held both CPA and enrolled agent credentials. After a period of discipline, OPR restored his right to practice before the IRS effective July 2025. Reinstatement decisions signal that OPR focuses not only on punishment, but also on future compliance and professional conduct.
Common triggers for OPR sanctions
OPR discipline usually follows serious misconduct, not simple mistakes. Common triggers include willfully failing to file or pay personal taxes, preparing or assisting with false returns, participating in abusive tax schemes, promoting improper refunds, or misleading clients about their rights and obligations.
Violations of conflict of interest rules, lack of due diligence, and failure to follow Circular 230 standards can also lead to sanctions.
Why OPR sanctions matter to taxpayers
For taxpayers, OPR’s disciplinary list is an important due diligence tool. A sanctioned practitioner cannot legally represent clients before the IRS, even if they still hold a valid state license.
Hiring a professional who is suspended or disbarred can delay your case, limit representation options, and create unnecessary risk. Taxpayers should verify both state licensing and IRS practice eligibility before engaging a representative.
What tax professionals should take away from OPR actions
OPR enforcement sends a clear message to tax professionals. Technical knowledge alone is not enough. Long term success requires ethical compliance, personal tax compliance, and adherence to Circular 230 standards.
Failing to meet those obligations can lead to public discipline, loss of practice rights, and lasting damage to a professional career. For many practitioners, appearing in an OPR disciplinary listing is far more damaging than any single audit or penalty.
Conclusion
OPR disciplinary sanctions highlight a less visible side of tax enforcement, one that directly targets the professionals who represent taxpayers. When ethical lines are crossed, the IRS can remove the privilege to practice before it.
For tax professionals, the lesson is clear. Compliance applies to you as much as it applies to your clients. Losing IRS practice rights is not theoretical. It happens, and when it does, careers can change overnight.