The short version
This is a review sheet, not a study course. It lists the exam facts, the pairs of rules people mix up, and the “if the scenario says X, think Y” shortcuts for each domain. It does not cover everything on the exam, and it is written in our own words. Tax rules change: any dollar amount, threshold, rate or date belongs to a specific tax year, so check it against that year’s IRS sources and the Candidate Information Bulletin before you rely on it. Facts below were checked October 22, 2026.
Exam facts at a glance
| Item | Detail |
|---|---|
| Parts | Part 3: Representation, Practices and Procedures |
| Questions | 100 multiple choice, 85 scored, 15 unscored |
| Time | 3.5 hours (appointment four hours) |
| Pass mark | 500 on a 200 to 800 scale |
| Sections | Questions 1-34, 35-67, 68-100; no going back after you confirm a section |
| Scored questions by domain | Practices and Procedures 26, Representation 25, Specific Areas 20, Filing Process 14 |
| Law cutoff | Law as amended through December 31, 2025; questions relate to calendar year 2025 |
| Retakes | Four attempts per part per window, 24 hours between attempts at one part |
| Carryover | Three years from the date you passed |
Domain 1: Practices and Procedures
Key concepts
- Circular 230 governs who may practice and how. Sanctions can follow incompetence, disreputable conduct and willful violations.
- Due diligence: you must act with care in preparing and advising, and you may rely in good faith on a client’s information unless it looks wrong or incomplete, in which case you ask.
- Client records belong to the client. You return them on request, even if the client has not paid. A narrow state-law exception lets you keep your own work product in a fee dispute, but you still hand over what the client needs to meet federal tax duties (31 CFR 10.28).
- Conflicts of interest generally need informed consent from each affected client, in writing, and you keep the consent for the period the rules give.
- Contingent fees are tightly limited. They are generally barred for preparing an original return, with narrow exceptions such as work in an examination or a court case.
- A practitioner may not endorse or cash a client’s refund check.
Easily confused pairs
- Preparer penalty for an unreasonable position (needs substantial authority, or a reasonable basis with disclosure) versus the penalty for willful or reckless conduct.
- Criminal disclosure rule (IRC 7216) versus civil disclosure penalty (IRC 6713).
- Disclosure of return information (consent needed) versus use of it for another purpose (consent also needed).
Decision rules
- If the stem says “client demands records back during a fee dispute”, think return the records.
- If it says “two clients with opposing interests”, think disclosure and written consent, or decline.
- If it says “advertising”, think accurate, not misleading, and no promises of results.
Traps: treating a rule’s exception as the rule; assuming consent can be oral.
Domain 2: Representation before the IRS
Key concepts
- Form 2848 gives a representative power to act. Form 8821 lets a named person receive or inspect information but not act.
- The Centralized Authorization File (CAF) number identifies a representative in IRS records.
- Build the case in order: authorization, transcripts, facts and documents, legal authority, position.
- Authority ranks: the Code and regulations carry the most weight, followed by court decisions and revenue rulings and procedures. IRS publications and manuals explain the IRS view and are not binding authority.
Easily confused pairs
- 2848 (acts for the taxpayer) versus 8821 (receives information only).
- Binding authority versus guidance that explains.
- Taxpayer’s financial picture for collection versus support for a tax position.
Decision rules
- “Needs to sign, negotiate or settle for the client” means 2848.
- “Only needs to see the account” means 8821.
- “Possible criminal exposure” means be careful about what the client says and what you submit.
Traps: assuming 8821 authorizes action; assuming a publication outranks the Code.
Domain 3: Specific Areas of Representation
Key concepts
- The tax lien arises by law after assessment, notice and demand, and non-payment. The notice of federal tax lien is the public filing. A levy takes property.
- Collection Due Process (CDP) has a short deadline tied to a specific notice (the final notice of intent to levy, or the lien notice). Missing it can leave you with an equivalent hearing and no Tax Court review. Read the deadline on the notice.
- The Collection Appeals Program (CAP) is a faster, informal route that is not tied to that deadline.
- Collection options: extension to pay, installment agreement, offer in compromise, currently not collectible status.
- Time limits: the IRS generally has three years from filing to assess, longer with a large omission of income, and no limit for fraud or an unfiled return. The IRS generally has ten years from assessment to collect, and certain events pause that clock.
- Audit path: 30-day letter, Appeals protest, notice of deficiency, Tax Court petition within the period on the notice.
Easily confused pairs
- Lien release, withdrawal, discharge and subordination.
- CDP versus CAP.
- 30-day letter versus notice of deficiency (the 90-day letter).
- Offer in compromise (settle for less) versus installment agreement (pay over time) versus currently not collectible (pause).
- Penalty abatement for reasonable cause versus first-time relief.
Decision rules
- “Taxpayer cannot pay and has little equity” suggests currently not collectible or an offer.
- “Taxpayer wants to challenge a levy before it happens” suggests CDP if in time.
- “Taxpayer agrees with the proposed change” suggests signing a waiver form, which generally gives up the chance to petition Tax Court on that notice.
Traps: forgetting that a request for a hearing or a pending offer can pause the collection clock; mixing up who has a right to Tax Court.
Domain 4: Filing Process
Key concepts
- An authorized IRS e-file provider follows the IRS e-file rules (Publication 1345), including signature authorization, security, and advertising standards.
- The electronic return originator (ERO) is the one who originates the e-filed return and holds the signature authorization.
- Form 8879 is the signature authorization the ERO keeps. Form 8453 is the transmittal sent with paper attachments that cannot be e-filed.
- Form 8948 explains why a preparer’s return was filed on paper.
- Keep a copy or list of returns you prepared for the period the Code requires.
- Protect client data. A written security plan is expected, and software output is not proof that a return is right.
Easily confused pairs: ERO versus transmitter; 8879 versus 8453; 8948 (paper filing reason) versus 8944 (request to be excused from e-filing).
Decision rules: “keeps the signature authorization” means ERO and 8879; “paper attachments go with the e-file” means 8453.
Traps: assuming the software checked the law; confusing infraction levels.
Last-day checklist
- Your ID matches your registration, and you know where to be and when.
- You can state each pair above in one sentence.
- You know which deadlines come with which notice.
- You remember that “except” questions flip the logic.
- You confirm each section only after you reviewed it.
- You know the window and law cutoff apply to calendar year 2025 for this window.
More guides for SEE-PART-3
- SEE Part 3 Exam Format, Scoring, Retakes
- SEE Part 3 Study Plan: 4 and 8 Weeks
- Is SEE Part 3 Hard? An Honest Look
- SEE Part 3 Prerequisites and Self-Check
- SEE Part 3 Renewal and Retakes Explained
- Is SEE Part 3 Worth It? An Honest Look
- SEE Part 2 vs Part 3: Which First?
Next step
Turn the pairs into questions with the sample questions and read the domains explained page for more detail. The SEE Part 3 overview lists the other guides, and our SEE Part 3 practice exams give you more scenarios to test yourself.