Some taxpayers are receiving CP59SN notices even though they filed valid extensions for their 2024 returns, pushing their due date to Oct. 15, 2025. This appears to be part of a broader issue within the IRS’s notice system. As a trusted tax professional, it’s important to understand what’s happening and what to communicate to clients.

What is a CP59SN notice?

A CP59SN notice is sent by the IRS when its records indicate a taxpayer has not filed a return. The “SN” variant refers to specific groups of nonfilers, often identified by third-party information the IRS has received, such as W-2s or 1099s. These notices are designed to prompt taxpayers to file or provide an explanation.

Why the notices are problematic

There are reports on social media of multiple instances where taxpayers received these notices despite filing a timely extension with the IRS earlier this year. These extensions give taxpayers until Oct. 15, 2025, to file their returns. In addition to these accounts, the AICPA has reported that it is in communication with the IRS regarding the issue.

The issue seems to stem from the IRS not properly recognizing or processing the extensions before issuing the CP59SN notices. Although the IRS has not released an official statement acknowledging a systemic error, the consistency and timing of these reports indicate this may be more than isolated incidents.

What you should do

If your clients receive a CP59SN notice despite having a valid extension on file, here’s how to respond:

Confirm the extension

Review your records and confirm that the extension was filed and accepted. If you submitted it electronically, you should have an acknowledgment receipt.

Check the client’s IRS transcript

Use your IRS e-Services account to view the taxpayer’s account transcript. This will show whether the extension was received and processed.

Advise the client not to panic

Reassure your client that if a valid extension was filed, they are not in violation and the notice is likely incorrect.

Respond if necessary

While not always required, you may choose to respond to the notice with a copy of the extension acknowledgment to help prevent additional notices or confusion.

Continue monitoring the IRS for updates

If the IRS formally addresses the issue, we will share the update with our members.

NATP is listening

We’re actively monitoring this situation and encourage members to report any additional instances. Your experiences help us advocate for clear communication from the IRS and practical resolutions for issues that impact your clients.

Tax professionals must maintain an active preparer tax identification number (PTIN) to legally prepare federal tax returns for compensation.

The Steele v. United States ruling, released last week by the U.S. Court of Appeals for the D.C. Circuit, confirms that the IRS can indeed require paid preparers to obtain and renew a PTIN. This ruling reinforces the foundation of IRS oversight of the paid preparer community, a key component in protecting taxpayers and the integrity of the tax system.

The court did not conclusively decide whether the current PTIN fee amount is reasonable in all respects, leaving the door open for future challenges. Importantly, this was a procedural defeat for the preparers: the court ruled their challenge could not proceed under current legal standards but did not conclude that the current PTIN fee structure is unquestionably reasonable or fair.

PTIN basics and renewal costs

A PTIN is a unique identification number issued by the IRS to individuals authorized to prepare federal tax returns for compensation. Anyone who prepares or assists in preparing federal returns for pay must have a valid PTIN before doing so. PTINs belong to the individual, not the business or firm.

PTINs must be renewed annually by submitting Form W-12, IRS Paid Preparer Tax Identification Number (PTIN) Application and Renewal, to the IRS and paying the applicable fee; the 2025 renewal cost is $19.75, comprised of $11 for the IRS fee, plus a separate $8.75 fee charged by a third-party contractor. This can be submitted online using the IRS portal.

Short history of the Steele case

The Steele litigation has been ongoing for more than a decade. In 2014, a group of preparers filed a suit, arguing that PTIN fees were excessive and that the IRS lacked authority to require a PTIN. Over time, courts consistently recognized that the IRS possesses statutory authority to require PTINs but questioned whether the amount charged was reasonable. Earlier decisions resulted in the IRS lowering the fee from $30.75 to $11 as of October 2023, reflecting the actual costs incurred by the agency in administering the PTIN program.

What was challenged in the Steele case?

The plaintiffs in Steele argued that the IRS lacked statutory authority to require PTINs and that the fees charged were excessive and unjustified. They claimed that the PTIN program served no legitimate regulatory purpose and placed undue financial burdens on preparers, especially those who prepare only a small number of returns each year.

What did the court say (and what it didn’t)?

The D.C. Circuit upheld the IRS’s authority to require PTINs, reaffirming that the agency has discretion to regulate who practices before it and how they are identified. However, the court did not definitively rule that the current PTIN fee structure is unassailable. In essence, this was a procedural defeat for the challengers: the court rejected their arguments but left open the possibility that future litigation could test the reasonableness of the fees. The key takeaway is that this ruling confirms the requirement to maintain an active PTIN but does not foreclose all debate about fee amounts.

Take action with NATP

The Steele decision makes clear that a valid PTIN is required to prepare federal tax returns for compensation. Renew annually using Form W-12 and pay the correct fees. To assist in staying compliant, follow NATP for the latest IRS updates, practical guidance and tools to keep your business ahead. We’ll continue to monitor any further litigation on PTIN fees and update members accordingly.

The centralized partnership audit regime (CPAR) reshaped how the IRS audits partnerships, shifting audits from partners to the partnership itself. What does this mean for tax professionals advising partnerships today?

Why CPAR matters to your clients

CPAR affects every partnership, from small partnerships to large ones.

• Centralized audits: The IRS audits and assesses tax at the partnership level, not the individual partner level, resulting in streamlined collections.
• Created liability shifts: Current partners can become liable for taxes on income earned in years prior to their partnership.
• Required proactive elections: Partnerships eligible to opt out must file timely elections each year to avoid entity-level assessments.

Example: Partnership-level liability

Riverstone Architects LLC opened for business on Jan. 1, 2024, with three equal individual partners. Suppose the IRS later audits Riverstone’s 2024 Form 1065, U.S. Return of Partnership Income, and finds unreported income. In that case, the entire assessment would initially be billed to Riverstone itself in the year the audit is completed (the adjustment year), rather than to the three partners on their individual 2024 income tax returns.

Suppose Riverstone understated $90,000 of architect fees (income) on its 2024 Form 1065. During a 2027 audit, the IRS proposes an adjustment. Absent any special election, Riverstone would pay the imputed underpayment due in 2027, even though the income related to its 2024 operations.

Key CPAR features tax pros must know

Opting out of CPAR

Eligible partnerships can elect out annually. However:

• The partnership must have 100 or fewer partners at all times during the tax year, and all partners must be eligible partners.
• The election is made by filing Schedule B-2 (Form 1065), Election Out of the Centralized Partnership Audit Regime, with a timely Form 1065 and notifying the partners within 30 days.

Consistency in partner reporting

Partners must report items exactly as shown on Schedule K-1 (Form 1065), Partner’s Share of Income, Deductions, Credits, etc., unless they file Form 8082, Notice of Inconsistent Treatment. Failure to do so can result in direct partner-level tax and penalties.

Push-out election

Instead of paying at the partnership level, a partnership can elect to “push out” the adjustments to the partners:

• Timing: The election must be made within 45 days of the final partnership adjustment notice.
• Process: The partnership must provide each reviewed-year partner (i.e., partners during the tax year being audited) and the IRS a statement of each partner’s share of the adjustments as determined in the notice of final partnership adjustment.
• Binding election: Once made, the election is irrevocable unless the IRS allows otherwise.

This approach allows the tax consequences of adjustments to be handled at the partner level, rather than by the partnership itself.

Example: Ortega Brewery was audited in 2025 for its 2022 tax year and was determined to have underreported its income. It can elect to push out the adjustment, making the partners from 2022 (instead of the current partners) liable for the additional tax.

No push-out election

If a partnership doesn’t elect to push out, it pays the imputed underpayment itself in the adjustment year, regardless of partner changes since the audited year.

Why this matters for your practice

Understanding CPAR ensures you can:

• Advise clients on whether to elect out each year
• Prepare for potential partnership-level liabilities
• Guide partners on reporting consistency to avoid penalties
• Navigate push-out elections to minimize tax impact for current partners

Final takeaway

CPAR fundamentally changes partnership audits, placing responsibility on the entity instead of the partners. To avoid surprises, stay proactive by reviewing election eligibility annually and discussing these rules with your partnership clients.

Learn more about CPAR by purchasing the Preparing Partnership Returns self-study.