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24.1 Two Paths to EA (Exam vs. IRS Experience)

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Enrolled Agent EA

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1 Part 1, Chapter 1: Tax Return Basics & Filing Requirements

1.1 Form 1040 Overview & Structure 1.2 Form 1040-SR for Seniors 1.3 Who Must File (Income Thresholds) 1.4 Filing Deadlines & Extensions (Form 4868) 1.5 Penalties: Failure to File vs. Failure to Pay 1.6 Sources of Tax Information (W-2s, 1099s, K-1s) 1.7 Preparer Due Diligence Requirements 1.8 Amended Returns (Form 1040-X)

2 Part 1, Chapter 2: Filing Status & Dependents

2.1 Single & Married Filing Jointly 2.2 Married Filing Separately 2.3 Head of Household Requirements 2.4 Qualifying Surviving Spouse 2.5 Qualifying Child Test (5 Tests) 2.6 Qualifying Relative Test (4 Tests) 2.7 SSN, ITIN & Residency Status

3 Part 1, Chapter 3: Wages & Employee Compensation

3.1 W-2 Income & Withholding 3.2 Employee vs. Independent Contractor 3.3 1099-NEC, 1099-MISC & 1099-K Reporting 3.4 Fringe Benefits (Taxable vs. Non-Taxable) 3.5 Stock Options (ISO vs. NQSO) 3.6 Special Categories (Clergy, Military, Foreign)

4 Part 1, Chapter 4: Interest, Dividends & Other Income

4.1 Taxable vs. Tax-Exempt Interest 4.2 US Savings Bonds & OID 4.3 Ordinary vs. Qualified Dividends 4.4 Schedule B Requirements 4.5 Rental & Royalty Income Basics 4.6 Alimony, Gambling & Other Income 4.7 Cancelled Debt & Form 1099-C 4.8 Net Operating Loss (NOL)

5 Part 1, Chapter 5: Capital Gains & Property Transactions

5.1 Capital vs. Non-Capital Assets 5.2 Cost Basis Calculation 5.3 Inherited & Gifted Property Basis 5.4 Short-Term vs. Long-Term Gains 5.5 Capital Gains Tax Rates (0%, 15%, 20%) 5.6 Netting & the $3,000 Loss Limit 5.7 Wash Sales & Related Party Rules 5.8 Sale of Primary Residence (Section 121) 5.9 Installment Sales (Form 6252) 5.10 Like-Kind Exchanges (Section 1031)

6 Part 1, Chapter 6: Adjustments to Income

6.1 Educator Expenses & HSA Contributions 6.2 Self-Employment Tax Deduction 6.3 IRA Contributions (Traditional) 6.4 Student Loan Interest Deduction 6.5 Alimony Paid (Pre-2019 Divorces) 6.6 Other Adjustments & New OBBBA Deductions (Tips, Overtime, Auto Loan, Senior Bonus)

7 Part 1, Chapter 7: Deductions (Standard & Itemized)

7.1 Standard Deduction by Filing Status 7.2 Medical & Dental Expenses (7.5% Floor) 7.3 State & Local Taxes (SALT $40K Cap) 7.4 Mortgage Interest Deduction 7.5 Charitable Contributions 7.6 Casualty & Theft Losses 7.7 QBI Deduction (Section 199A)

8 Part 1, Chapter 8: Tax Calculation & Credits

8.1 Tax Tables & Rate Schedules 8.2 Alternative Minimum Tax (AMT) 8.3 Self-Employment Tax Calculation 8.4 Child Tax Credit & Additional CTC 8.5 Earned Income Tax Credit (EITC) 8.6 Education Credits (AOC & LLC) 8.7 Child & Dependent Care Credit 8.8 Other Credits (Saver's, Premium Tax)

9 Part 1, Chapter 9: Retirement Accounts & Social Security

9.1 Traditional vs. Roth IRA 9.2 401(k), 403(b) & TSP Basics 9.3 SEP-IRA & SIMPLE IRA 9.4 Required Minimum Distributions (RMDs) 9.5 Early Withdrawal Penalties & Exceptions 9.6 Social Security Taxation

10 Part 1, Chapter 10: Specialized Individual Returns

10.1 Estate Tax (Form 706) 10.2 Gift Tax (Form 709) 10.3 Foreign Income (Form 2555) 10.4 FBAR & FATCA Reporting 10.5 Farm Income (Schedule F) 10.6 Disaster Area Rules

11 Part 2, Chapter 11: Business Entity Types

11.1 Overview of Entity Types 11.2 State Law vs. Tax Classification 11.3 Entity Selection: Reasonable Comp & QBI 11.4 Form 8832 & Rev. Proc. 2009-41 11.5 LLC Deep Dive: Spouses & EINs 11.6 Changing Status: The 60-Month Rule

12 Part 2, Chapter 12: Starting a Business

12.1 Hobby vs. Business (Profit Motive) 12.2 Employer Identification Number (EIN) 12.3 Tax Year Selection 12.4 Recordkeeping Requirements 12.5 Statute of Limitations 12.6 Related Party Transactions 12.7 Start-Up Costs, Entity Choice & OBBBA Business Changes (2025)

13 Part 2, Chapter 13: Worker Classification & Payroll

13.1 Employee vs. Independent Contractor 13.2 Common Law Test (Behavioral, Financial, Relationship) 13.3 Statutory Employees & Non-Employees 13.4 Form 941 & Payroll Deposits 13.5 Trust Fund Recovery Penalty 13.6 FUTA & Unemployment Taxes

14 Part 2, Chapter 14: Accounting Methods & Income

14.1 Cash vs. Accrual Method 14.2 Hybrid Methods & Changes 14.3 Inventory & COGS 14.4 Gross Receipts & Income Recognition 14.5 Constructive Receipt 14.6 Form 1099 Reporting Requirements 14.7 §163(j) Business Interest Expense Limitation 14.8 §174 Research & Experimental Expenditures

15 Part 2, Chapter 15: Depreciation & Asset Treatment

15.1 MACRS Basics & Recovery Periods 15.2 Mid-Month, Mid-Quarter, Half-Year Conventions 15.3 Section 179 Expense Deduction 15.4 Bonus Depreciation 15.5 Listed Property Rules 15.6 Amortization of Intangibles 15.7 Depletion 15.8 Disposition of Business Assets

16 Part 2, Chapter 16: Business Deductions

16.1 Ordinary & Necessary Test 16.2 Business Travel Expenses 16.3 Business Meals (50% Limitation) 16.4 Business Use of Vehicle 16.5 Home Office Deduction 16.6 Business Interest Limitation (163(j)) 16.7 Business Bad Debts

17 Part 2, Chapter 17: Business Credits & Fringe Benefits

17.1 General Business Credit Overview 17.2 R&D Credit & Disabled Access Credit 17.3 Small Employer Health Insurance Credit 17.4 Fringe Benefit Rules 17.5 Cafeteria Plans (Section 125) 17.6 Achievement Awards & Other Benefits

18 Part 2, Chapter 18: Sole Proprietorships

18.1 Schedule C Overview 18.2 Calculating Net Profit/Loss 18.3 Self-Employment Tax (Schedule SE) 18.4 Estimated Tax Payments 18.5 Hobby Loss Rules

19 Part 2, Chapter 19: Partnerships

19.1 Partnership Formation 19.2 Partner's Basis Calculation 19.3 Form 1065 Overview 19.4 Schedule K-1 (Partner's Share) 19.5 Guaranteed Payments 19.6 Partnership Distributions 19.7 At-Risk & Passive Activity Rules 19.8 Partnership Termination & Liquidation

20 Part 2, Chapter 20: C Corporations

20.1 Form 1120 Overview 20.2 Corporate Tax Rate (21%) & CAMT 20.3 Accumulated Earnings Tax 20.4 Dividends Received Deduction 20.5 Earnings & Profits (E&P) 20.6 Corporate Distributions, Dividends & Stock Redemptions 20.7 §351 Transfers, §1032, §1202 QSBS & Other Corporate Provisions 20.8 Corporate Liquidation

21 Part 2, Chapter 21: S Corporations

21.1 S Election Requirements (Form 2553) 21.2 Form 1120-S Overview 21.3 Shareholder Basis Calculation 21.4 Reasonable Compensation 21.5 S Corporation Distributions 21.6 Built-In Gains Tax & Termination

22 Part 2, Chapter 22: Specialized Business Returns

22.1 Trusts & Estates (Form 1041) 22.2 Simple vs. Complex Trusts 22.3 Distributable Net Income (DNI) 22.4 Tax-Exempt Organizations (Form 990) 22.5 Retirement Plans (Form 5500) 22.6 Qualified Retirement Plans Overview 22.7 Farm Taxation 22.8 Rental Real Estate Activities

23 Part 3, Chapter 23: Practice Before the IRS

23.1 What is Practice Before the IRS? 23.2 Who Can Practice (Full Rights) 23.3 Limited Practice Rights (AFSP, Unenrolled) 23.4 Special Relationships (Family, Employees) 23.5 PTIN Requirements 23.6 Circular 230 Overview 23.7 Office of Professional Responsibility (OPR)

24 Part 3, Chapter 24: Becoming & Maintaining EA Status

24.1 Two Paths to EA (Exam vs. IRS Experience) 24.2 Application Process (Form 23) 24.3 Background & Compliance Checks 24.4 Renewal Requirements (Form 8554) 24.5 Continuing Education Requirements 24.6 Inactive Status & Termination

25 Part 3, Chapter 25: Practitioner Duties (Circular 230)

25.1 Due Diligence Requirements 25.2 Knowledge of Client's Omission 25.3 Conflict of Interest Rules 25.4 Fee Requirements (Contingent, Unconscionable) 25.5 Advertising & Solicitation Rules 25.6 Tax Return Position Standards 25.7 Written Advice Standards 25.8 Sanctions & Penalties for Violations

26 Part 3, Chapter 26: Power of Attorney & Authorization

26.1 Form 2848 (Power of Attorney) 26.2 CAF (Centralized Authorization File) 26.3 Form 8821 (Tax Information Authorization) 26.4 Third-Party Designee 26.5 Signing Returns for Taxpayers 26.6 Client Confidentiality & Privilege 26.7 Representing Clients in Audits (Examination) 26.8 Appealing IRS Decisions 26.9 Collection Representation

27 Part 3, Chapter 27: Legal Authority & Research

27.1 Hierarchy of Tax Authority 27.2 Internal Revenue Code 27.3 Treasury Regulations 27.4 Revenue Rulings & Procedures 27.5 Court Cases & Precedent 27.6 Statutes of Limitations

28 Part 3, Chapter 28: Specific Representation Issues

28.1 Trust Fund Recovery Penalty (TFRP) 28.2 Innocent Spouse Relief (Form 8857) 28.3 Injured Spouse Allocation (Form 8379) 28.4 Penalty Abatement (FTA & Reasonable Cause) 28.5 Taxpayer Advocate Service (TAS) 28.6 Freedom of Information Act (FOIA)

29 Part 3, Chapter 29: Final Review & Exam Strategy

29.1 Exam Structure & Logistics (2026-2027) 29.2 The "Clock" of Representation (Master Deadlines) 29.3 Ethics vs. Law (Sanctions & Penalties) 29.4 Final Mock Review & Exam Strategy

30 Part 3, Chapter 30: Filing Process & E-File

30.1 E-File Requirements (The "More Than 10 Returns" Rule) 30.2 ERO Responsibilities 30.3 EFIN & Application Process 30.4 Form 8879 (Signature Authorization) 30.5 Record Retention & Data Security (WISP) 30.6 Preparer Penalties (Filing Specific)

24.1 Two Paths to EA (Exam vs. IRS Experience)

Key Takeaways Explain This Topic AI

Path 1: Pass all 3 parts of the Special Enrollment Examination (SEE) administered by PSI Services (PSI replaced Prometric on March 1, 2026).

Path 2: 5 years of qualifying IRS experience in technical positions interpreting tax law.

SEE Parts: Part 1 Individuals, Part 2 Businesses, Part 3 Representation/Practices/Procedures.

2026-2027 testing window: July 1, 2026 - February 28, 2027 (US domestic); March-April blackout for exam updates.

Per-part fee: $317 ($66 IRS user fee + $251 PSI vendor fee) for the 2026-2027 cycle; three parts total $951.

Both paths require Form 23 ($140 fee), active PTIN, IRS suitability check (tax compliance + criminal background) handled by the IRS Office of Enrollment, not OPR.

Last updated: October 2026

  • Two Paths to Enrolled Agent Status
  • Why This Matters for the Exam

Understanding how one becomes an Enrolled Agent is foundational for Part 3. The exam tests your knowledge of the two paths, the SEE requirements, and the IRS experience alternative.

Exam Note: For the July 1, 2026 - February 28, 2027 testing window , you are tested on EA enrollment requirements and tax law as of December 31, 2025 (Tax Year 2025, post-OBBBA).

Vendor Transition (IMPORTANT): Prometric, LLC administered the SEE through the February 28, 2026 close of the previous window. PSI Services LLC took over as the IRS's SEE testing vendor on March 1, 2026. Every current candidate registers, schedules, pays, and tests through PSI — not Prometric.

Overview of the Two Paths

Path Method Key Requirement

Path 1 Special Enrollment Examination (SEE) Pass all 3 parts; each passed part carries over for three years from the date it was passed

Path 2 IRS Experience 5 years technical IRS experience

Both paths require:

IRS suitability check (tax compliance review + criminal background check) administered by the IRS Office of Enrollment , the office that acts on enrollment applications (the Office of Professional Responsibility handles discipline).

Form 23 application with $140 fee (submitted online via Pay.gov or by mail).

Active PTIN (annual renewal fee $18.75 for 2026).

Path 1: Special Enrollment Examination (SEE)

The SEE is the most common path to becoming an Enrolled Agent. PSI Services administers the SEE on behalf of the IRS effective March 1, 2026 (replacing Prometric).

The Three Parts

  • Part Name Content
  • Part 1 Individuals Individual income tax returns, filing requirements, income, deductions, credits
  • Part 2 Businesses Business entities, accounting periods, partnerships, corporations, trusts
  • Part 3 Representation, Practices & Procedures Circular 230, representation, ethics, IRS procedures
  • Exam Specifications (2026-2027 Cycle)
  • Specification Detail
  • Questions per part 100 multiple choice (85 scored + 15 unscored pretest)
  • Time per part 3.5 hours
  • Passing score Scaled score of 500 on a 200–800 scale; no published raw-percentage conversion
  • Per-part fee $317 — $66 IRS user fee + $251 PSI vendor fee
  • Total for 3 parts $951
  • Testing window (2026-2027) July 1, 2026 - February 28, 2027 (US domestic)
  • Scheduling opens May 1, 2026 (US domestic); international scheduling/testing delayed as of October 11, 2026

International rollout International scheduling and testing delayed; no new start date announced as of October 11, 2026

  • Closed period March 1 - April 30 (exam updates — unchanged)
  • Fee History (For Context)
  • Period Per-Part Fee Notes
  • Pre-2024 $206 Prometric era
  • 2024-2025 $259 / $267 Prometric era ($99 IRS user fee + contractor fee)

2026-2027 cycle $317 $66 IRS user fee (Federal Register interim final rule, registrations on or after April 20, 2026) + $251 PSI vendor fee

The 3-Year Carryover Window

Each passed part carries over for three years from the date you passed it :

If you do not pass the remaining parts before a passed part's three-year period ends, you lose credit for that part and must pass it again.

You can retake a part up to 4 times per testing window , with a mandatory 24-hour wait after a failed attempt before re-scheduling that same part.

There is no lifetime limit on retakes — but you pay the $317 fee each time.

Example:

Pass Part 1 on August 1, 2026.

Pass Parts 2 and 3 by August 1, 2029, or Part 1's credit expires.

If Part 1 expires first, you must pass Part 1 again.

Path 2: IRS Experience

Former IRS employees may qualify for enrollment based on technical experience.

Requirements

  • Requirement Detail
  • Years of experience 5 years
  • Type of experience Interpreting and applying tax code and regulations

Qualifying positions Revenue Agent, Tax Law Specialist, Appeals Officer, etc.

  • SEE requirement May request waiver (not automatic; the IRS reviews qualifying experience)
  • Background check Still required
  • Form 23 Still required ($140 fee)

Key Point: Not all IRS experience qualifies. The experience must be in technical tax positions involving interpretation of tax law.

Comparison: SEE vs. IRS Experience Path

  • Factor SEE Path IRS Experience Path
  • Time to qualify Variable (pass 3 exams) 5 years IRS employment
  • Cost (exam fees) $951 ($317 × 3 parts) N/A
  • Form 23 fee $140 $140
  • Background check Required Required
  • PTIN Required ($18.75/yr) Required ($18.75/yr)
  • Most common Yes No
  • Real-World Scenario

Scenario: You passed Part 1 of the SEE on August 15, 2026 (PSI testing center, $317 fee). You pass Part 2 on January 10, 2027. When is the deadline to pass Part 3 for enrollment purposes?

Answer: August 15, 2029, three years after passing Part 1. If Part 3 is not passed by then, Part 1's credit expires (Part 2 stays credited until January 10, 2030).

Important: Each passed part carries over for three years from the date it was passed; there is no separate 2-year rule.

On the Exam

Question types to practice on EA paths:

  • SEE Structure Questions: "How many parts does the SEE have?"
  • Time Limit Questions: "Within what time frame must all SEE parts be passed for enrollment?"
  • IRS Experience Questions: "How many years of IRS experience are required?"
  • Vendor/Fee Questions: "Who administers the SEE?" or "What is the per-part SEE fee?"

The key is to remember: SEE = 3 parts, completed within the three-year carryover period measured separately from each passed part for enrollment, $317 per part, PSI Services administers (post-March 2026). IRS = 5 years technical experience. Both require Form 23 ($140) and the IRS suitability check.