Representing taxpayers with IRS identity protection and theft victim assistance

Editor: Arthur Auerbach, CPA, CGMA

In addition to the standard responsibilities of preparing and filing tax returns, tax professionals are often called upon to assist with issues related to taxpayer accounts as authorized representatives via Form 2848, Power of Attorney and Declaration of Representative.

As identity theft cases continue to rise annually, requests for help resolving suspected or confirmed identity theft issues are increasing for tax practitioners. These cases can be particularly challenging due to the IRS’s privacy and security protocols.

The IRS has implemented a range of strategies to detect, prevent, and respond to suspected identity theft. This column provides an overview of the Service’s identity theft protocols and explores how tax advisers can assist clients in responding to and resolving these issues.

IRS Taxpayer Protection Program

Established in 2012, the Taxpayer Protection Program (TPP) is the IRS’s primary tool for identifying and handling suspected identity theft and fraudulent tax returns. The program aims to detect suspicious activity during return processing. When the IRS flags suspicious activity, it halts processing and sends a verification notice requiring the taxpayer to confirm their identity before issuing any refunds.

For the 2024 filing season, the TPP identified and suspended nearly 2 million returns for identity verification (Taxpayer Advocate Service, “Identity Verification and Your Tax Return” (Feb. 24, 2025)).

Triggers for identity verification notices

Verification notices may be triggered by various factors, including:

• Early-season filings with high refund claims;
• Rejected e-filed returns (due to a prior filing under the same taxpayer identification number);
• Data mismatches (e.g., income or credits vs. third-party reporting);
• First-time filers;
• Unusual refund activity; and
• Changes in account details (e.g., address, name, or direct deposit).

IRS identity theft notices

Each notice has different response requirements. Carefully review the notice to determine the appropriate action.

Letter 5071C

• Sent when a suspicious return is filed under a taxpayer’s Social Security or individual taxpayer identification number.
• Offers online verification via idverify.irs.gov.

Letter 4883C

• Requires phone verification via the number shown on the letter.
• No online option available.
• The taxpayer must have the return in question, prior-year returns, and supporting documents available during the call.

Letter 5747C

• Requests that a taxpayer who did not file a return call the TPP hotline (number below).
• Requests that a taxpayer who did file a return call the Taxpayer Assistance Center (TAC) at the number on the letter (also below) to schedule an in-person appointment at a TAC.

Letter 5447C

• Sent to taxpayers outside the United States.
• Offers online or phone verification options.

Responding to identity theft notices

According to the Taxpayer Advocate Service (TAS), taxpayers took an average of 52 days to respond to IRS identity authentication notices during the 2023 filing season, with some taking more than six months (TAS, “Study Why Taxpayers Often Take a Long Time to Authenticate Their Identity to Receive a Claimed Refund” (updated April 29, 2025)). Once an identity is verified, the IRS advises, it may take up to nine weeks to process the return (IRS webpage, “Verify Your Return,” help topic “Your Refund”). The required response to a notice depends on whether the taxpayer has filed a return.

If the taxpayer did not file a return: Call the TPP phone line (number below) to confirm. The IRS will stop processing the suspicious return and withhold the refund.

If the taxpayer did file a return: Review the verification notice carefully and gather the following documentation:

• The notice itself;
• A copy of the tax return in question;
• A prior-year tax return;
• Supporting documents (Forms W-2, Wage and Tax Statement, 1099, etc.); and
• Identification documents.

Then assist the taxpayer in verifying their identity in one of the ways described below.

Challenges when representing clients

Missing or misplaced notices

If the taxpayer did not receive the notice, check their IRS online account. If it is unavailable, call the TPP line:

• Domestic: 800-830-5084.
• International: 267-941-1000.

Verifying online

To verify the taxpayer’s identity online, the taxpayer must have an ID.me account. The taxpayer will be asked to upload a photo of their identification, take a video selfie with a webcam or phone, and answer various security questions based on credit and tax history. While online verification is more convenient and does not require long hold times like the phone option, there is no way for an authorized representative to complete the online verification on behalf of a taxpayer client. As a best practice to assist clients, tax practitioners should consider scheduling time with the client to walk them through the process. This can be done either in person or virtually with a screen share.

Verifying over the phone

Verification over the phone presents several challenges for both taxpayers as well as taxpayer representatives. First, having the taxpayer on the line is not only beneficial but sometimes imperative to answer the questions presented. When verifying over the phone, the IRS does not have the same ability to review identification documents or receive an image of the taxpayer. As such, to properly verify the individual’s identity, the IRS asks deeply specific and personal questions, which can be difficult, if not impossible, for a representative to answer without the taxpayer present. For example, the IRS may ask for the taxpayer’s parents’ names or information about mortgage, credit card, or student loan accounts.

The second challenge is scheduling–related. There is no scheduling option, and the TPP phone line tends to be extremely busy, with long hold times and periodic disconnections. This can make coordinating with a client difficult, as it is impossible to predict how long it will take to get connected with an agent. Please note that if the taxpayer or representative is not able to answer the questions, the taxpayer or representative will then have to schedule an in–person appointment at a TAC.

Verifying in person

If verification is not possible online or over the phone, it must be done in person. To schedule the appointment, the authorized representative can call 844–545–5640 to schedule an appointment at a TAC. When verifying an individual in person, the IRS requires proof of identity and date of birth. Generally, this will consist of a valid federal or state government–issued picture identification, such as a driver’s license, state identification, or passport and one of the following forms of identification:

• Current federal or state government-issued identification that is different from the first document provided;
• U.S. Social Security card;
• Mortgage statement with current address;
• Lease agreement for a house or apartment with current address;
• Car title;
• Voter registration card (not the voter registration application);
• Utility bill matching the address on the taxpayer’s government-issued identification;
• Birth certificate; or
• Current school records (for taxpayers up to age 24).

Other considerations

While the above steps will help protect taxpayers against identity theft on current–year returns, taxpayers should consider enrolling in the annual Identity Protection PIN (IP PIN) program. When taxpayers are enrolled in the IP PIN program, the IRS will assign them a unique six–digit personal identification number (PIN) each December before the upcoming filing season. The IP PIN will be required to be affixed to the return. The IRS will not process a return without the correct IP PIN identified.

Taxpayers should also monitor their IRS account and credit reports for any unusual activity.

Proactive measures

As the IRS continues to strengthen its efforts to detect and prevent identity theft and fraudulent tax return processing, it is essential for tax practitioners to stay informed about the factors that may trigger an identity verification notice. Proactive measures taken before and during filing season can significantly reduce the risk of such notices and help resolve them efficiently if they occur. Key steps include:

• Client education: Inform clients ahead of filing season about the IRS identity protection and victim assistance programs and the potential for refund delays due to identity verification requirements.
• IRS account access: Enroll in and maintain access to clients’ IRS accounts to ensure timely receipt of notices and facilitate prompt resolution of identity verification issues.
• Prefiling review: Request and examine account transcripts before filing to confirm that all third-party reported income is accurately reflected on the tax return.
• Familiarity with notices: Understand the different types of IRS identity verification notices and the appropriate response procedures for each.

By implementing these practices, tax practitioners can better safeguard their clients and streamline the resolution process should identity verification issues arise.

---

Contributors

Sophie A. Pedersen, J.D., is a senior manager, Business Tax Advisory, with Ernst & Young LLP in Chaska, Minn. Arthur Auerbach, CPA, CGMA, is an independent tax consultant in Atlanta. Auerbach is chair and Pedersen is a member of the AICPA Tax Practice and Procedures Committee. For more information about this column, contact thetaxadviser@aicpa.org.