n-98-63.pdf

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December 7, 1998
ADVANCE COPY OF INTERNAL REVENUE BULLETIN ITEM
Attached is an advance copy of Notice 98-63, describing alternative identifying numbers
for preparers.
It will appear in Internal Revenue Bulletin 1998-51, dated December 21, 1998.
You may release this notice immediately.
Communications Division

Part III - Administrative, Procedural, and Miscellaneous
Alternative Identifying Numbers for Income Tax Return Preparers
Notice 98-63
PURPOSE
This notice informs income tax return preparers of the Service’s intention to develop a
system of providing alternative identifying numbers for preparers, as authorized by § 3710 of the
Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. No. 105-206, 112 Stat.
685 (the “Act”). Individual preparers are reminded of their continuing responsibility to furnish
their social security numbers (“SSNs”) on returns or claims for refund prepared by them.
LAW PRIOR TO AMENDMENT BY THE ACT
Section 6109(a)(4) of the Internal Revenue Code provides that any return or claim for
refund prepared by an income tax return preparer must bear the identifying number of the
preparer as required under regulations prescribed by the Secretary. Prior to its amendment by §
3710 of the Act, § 6109(a) of the Code provided that the identifying number of an individual
preparer was that individual’s SSN.
Section 1.6109-2 of the Income Tax Regulations provides that each return or claim for
refund prepared by an income tax return preparer must bear the identifying number of the
preparer, which, for an individual preparer, is that individual’s SSN.
EFFECT OF THE ACT
Under § 6109(a), as amended by § 3710 of the Act, the identifying number required for a
return preparer need not be the preparer’s SSN. Instead, the Secretary may issue regulations

providing alternatives to the SSN for purposes of identifying individual preparers. See § 6109(d).
To implement this change, the Service intends to develop a system for assigning
alternative identifying numbers to individual preparers. These alternative identifying numbers are
scheduled to be available for the filing season beginning January 1, 2000. The Secretary intends
to amend § 1.6109-2 to allow individual preparers the option of electing alternative identifying
numbers in lieu of their SSNs.
Until the alternative identifying numbers are available, § 1.6109-2 requires that individual
preparers continue to furnish their SSNs as their identifying numbers. However, as provided by
Rev. Rul. 78-317, 1978-2 C.B. 335, preparers may omit their SSNs from copies of returns
furnished to taxpayers under § 6107(a).
The Service will continue to monitor returns and claims for refund for the presence of
preparer SSNs. Income tax return preparers failing to furnish their SSNs on returns or claims for
refund are subject to a penalty of $50 for each such failure, as provided by § 6695(c).
DRAFTING INFORMATION
The principal author of this notice is Andrew J. Keyso of the Office of the Assistant Chief
Counsel (Income Tax and Accounting). Preparers may obtain updates on the status of the system
for assigning alternative identifying numbers by calling (202) 622-4405 (not a toll-free call).