February 21, 2018

In October 2017, an NAEA member received a visit from a Treasury Inspector General of Tax Administration (TIGTA) Special Agent who served her with a cease and desist letter with respect to her use of an IRS-approved EA logo on her business card.

NAEA was as troubled as anyone by this development. The government relations team reached out to IRS, asking for an explanation and clarification about the decision to prohibit use of the long-ago approved logo.

In early December 2017, IRS provided the following email response (reproduced below in its entirety) to NAEA:

“Though the IRS did create the logo around 2011 or 2012, the Office of Professional Responsibility later objected to it and advised that the use of the logo was not acceptable based on Circular 230 Section 10.30 and other rules because it contains IRS and the IRS eagle. It should not be used.”

NAEA found this email response insufficient to provide members with guidance on the use of the IRS-approved EA logo. We followed up with the agency with this letter and discussions with directors of both IRS’ Return Preparer Office and IRS’ Office of Professional Responsibility.

RPO Director Carol Campbell recently sent us a formal response to our February 21 letter. Director Campbell’s letter confirms EAs may no longer use the formerly approved IRS logo and provides a detailed explanation why. Further, and in response to NAEA requests, her letter states OPR will provide a grace period before it considers any disciplinary action under Circular 230 Section 10.30(a).

Next Steps

IRS will be releasing a new logo for EA use. Within six months of that release, EAs must delete the prior logo from advertising, websites, business cards and other communications. Please note that we have not included the draft logo referenced in Ms. Campbell’s letter, as IRS has not yet released it. NAEA will inform members when the new logo is available—and remind you use of the logo is voluntary.

NAEA thanks our members for their patience while we continue to work with IRS on this issue. Please contact Justin Edwards (jedwards@naea.org) should you have questions relating to the logo and its use.

The February 21 comment letter can be found here.