United States · Self-employed · Partnerships · Corporations

CPA Not Responding or Fired: Get Your Records and Books Back

Check the next due date and what the IRS shows was filed; neither waits for the old accountant. A CPA, enrolled agent or attorney generally must return your records, and an unpaid fee generally does not excuse holding documents you supplied. Have the new firm file Form 8821 or 2848, revoke the old access, and rebuild from one cutoff date.

Di Lu, CPA
Di Lu, CPAUS and Canadian CPA

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Tax year 2026 · Last updated  · Published by Cloud Accounting under standing professional approval

Who this is for

  • Sole proprietors, partnerships and corporations whose CPA or bookkeeper stopped answering or was let go
  • Owners who cannot tell which returns, extensions or payments the old accountant actually handled
  • Businesses that must rebuild their books from bank statements and IRS records

Not covered here

  • State income tax, sales tax and payroll-provider handovers
  • Fee disputes, malpractice and contract claims, which are legal matters
  • Preparing late returns, or setting opening balances in detail
  • Canadian accounts and records

My accountant stopped responding or I let them go: what do I do first?

Records you gave the accountant are yours, and the IRS keeps its own record of what was filed, so you can start without the old accountant. Work in this order:

  1. Find the next due date. A calendar-year Form 1065 or Form 1120-S is due March 15, or September 15 with an extension. A calendar-year Form 1120 is due April 15 of the following year, or October 15 with an extension. A sole proprietor's Schedule C is filed with Form 1040, due April 15, or October 15 with Form 4868. With payroll, Form 941 is due the last day of the first month after each quarter.
  2. See what the IRS has. Use a business tax account or order transcripts. Mailed transcripts go only to the address on file (step 5).
  3. Ask the old accountant in writing for your records, with a list and a date.
  4. Give the new firm authority on Form 8821 or Form 2848, and revoke the old firm's.
  5. Fix the address on file if IRS mail still goes to the old firm.
  6. Rebuild the books from one cutoff date.

Only step 3 needs the old accountant to answer.

A case is not simple when a due date is close or has passed with no proof of filing, when one or more years were never filed, when the IRS has sent a notice, when a loan or sale is pending, or when the last filed return and the books disagree. Those cases turn on what to file first, which is a judgment call for a professional; see the section on unfiled returns and notices below.

Gather: the EIN confirmation letter, any S-election or LLC-election acceptance letters, transcripts for each open year, bank and card statements for every account, payroll reports, and the last filed returns.

Which records are mine, and what must a former accountant hand back?

Under a federal rule, a CPA, enrolled agent or attorney must return, on request, the records you gave them and the records collected for you from others. A bookkeeper who prepares nothing for the IRS is not covered by that rule; the engagement letter and state law apply.

Treasury's rule says a practitioner must, at the client's request, promptly return any and all records of the client needed to meet the client's federal tax obligations, and may keep copies. The rule binds attorneys, CPAs and enrolled agents. By its terms it also reaches anyone paid to prepare all or a substantial portion of a return or other document for submission to the IRS.

Each state board of accountancy also sets rules for the CPAs it licenses. The Texas board's FAQ is one example, not a national rule. Check your own state board.

ItemYours to get back?
Documents you handed over: bank statements, invoices, payroll reports, prior returnsYes, under the federal rule. State rules can add a deadline: Texas, for example, requires a CPA to return these within 10 business days, with no fee.
Documents the firm collected for you that existed before it was hiredYes, under the federal rule.
Returns and schedules the firm prepared and gave you earlierYes, when you need them for a current federal filing.
A return or schedule the firm prepared and is holding until you pay the fee for that documentNot covered by the federal rule. Ask anyway, and settle that fee as a separate matter.
The firm's working papersGenerally the firm's. Texas, for example, requires working papers that are client records to be provided, for a reasonable fee.

The federal rule covers records you need for federal tax compliance. A ledger file or reconciliation reports may depend on your engagement letter, so ask for them anyway.

What exactly should I ask for?

Ask for everything that ties the last filed return to today, by year, in writing, with a delivery date and a file format.

Ask forWhy you need it
Filed returns for every open year, with all schedules, statements and e-file acknowledgmentsProof of what was filed; the starting point for opening balances
Form 7004 acknowledgments and payment confirmationsShow what was extended and what was paid
S-election, entity-classification and other IRS acceptance lettersThe elections bind later returns. A missing letter is a flag: see the last section
A backup of the accounting company file and administrator access, or an export of the ledger, trial balance and reconciliation reportsA rebuild is shorter when the old ledger survives
Fixed-asset and depreciation schedules; partner capital accounts or shareholder loan recordsThese carry from year to year and are hard to rebuild from bank statements
Payroll reports, Forms 941 and 940, W-2s and deposit historyPayroll returns run on their own calendar
Open IRS notices and any replies sentResponse dates keep running
A list of every login and bank connection set up in your nameSo you control them

Send the request by a method that proves delivery and keep a copy. If the accountant is a CPA, enrolled agent or attorney, cite the federal rule above.

Can they hold my files over an unpaid bill?

For a CPA, enrolled agent or attorney, a fee dispute generally does not excuse holding the client records the federal rule covers. Treasury's rule says the existence of a dispute over fees generally does not relieve the practitioner of the duty to return records. Two limits apply:

  • A return or schedule the firm prepared and is holding until you pay the fee for that document is not a client record under the rule.
  • Where state law lets a practitioner keep records during a fee dispute, the practitioner need only return the records that must be attached to your return, and must give you reasonable access to review and copy the rest.

The Texas FAQ is stricter: original documents you supplied must be returned on request, even if you have not paid. For a bookkeeper who is not covered by the federal rule, the contract and state law decide. Fee disputes and contract claims are legal questions this page does not answer.

Ask first for the originals you supplied, and settle the bill as a separate matter.

How do I see what the IRS has on file without my accountant?

Register for a business tax account if your role qualifies, or order transcripts by mail or phone. The IRS lists three ways to get a business transcript: the online account, Form 4506-T by mail, or the business and specialty tax line.

BusinessWho gets full access to the online accountLimited access, or limits
Corporation filing Form 1120 or 1120-SA Designated Official: an officer or managing member, a current employee who received a W-2 for the most recent filing year, and authorized to bind the entityAn S corporation shareholder with a K-1 sees balance, payments and transcripts for the years a K-1 is on file
Partnership filing Form 1065A Designated Official who is a general partner or a managing partner of the LLCA partner with a K-1 sees balance, payments and transcripts for the years a K-1 is on file
Sole proprietorSomeone with an SSN or ITIN and an EIN who files Schedule C or Schedule FNot yet available to an LLC that files as a sole proprietor

Source: IRS business tax account. Full access shows the balance, payment history, transcripts, and notices and letters. A Designated Official must renew the role every year. Limited access covers only the years the IRS lists as available, which may not include the latest ones. A single-member LLC that files Form 1120-S or Form 1065 can register only for limited access as a shareholder or partner with a K-1; the IRS lists its Designated Official role as coming soon. If you do not qualify, a sole proprietor's Schedule C is on the owner's personal transcripts, available through the individual online account or Form 4506-T.

TranscriptWhat it shows
Tax returnMost line items as originally filed. Not attached statements, and not later changes.
Tax accountFiling date, processing date, payments, penalties, interest and balance
Record of accountThe return and account transcripts combined
EntityEIN, filing requirements, and whether an LLC has one member or several

Return transcripts and records of account reach back only the current year and 3 prior years; account transcripts are available for most returns. Allow 2 to 3 weeks after e-filing and 6 to 8 weeks after mailing a paper return before you request a transcript. A "No record of return filed" message on a recent return may only mean it is not processed yet. Most Form 4506-T requests are processed within 10 business days. The IRS mails the transcript only to the address it has on file; if that is still the old accountant's, use the online account or update the address first (see the address section below). An officer with authority to bind the corporation, or any person who was a partner during part of the period, can sign the Form 4506-T.

A transcript is not a copy of the return. For the return as filed, with attachments, use Form 4506: $30 per return, up to 75 calendar days.

How do I tell which returns, extensions and payments were actually filed?

List what should exist for each year, then match each item to a transcript line or a filing acknowledgment. An item with neither is unproven.

What should existWhere to check
Form 1065, 1120-S or 1120 for each year, or the owner's Schedule CReturn and account transcripts show the filing and processing dates
Form 7004 extension (Form 4868 for an owner's Form 1040)For Form 7004, the account transcript: a processed request posts as transaction code 460 with the extended due date (IRM 3.12.212). Otherwise the e-file acknowledgment; the IRS sends no approval letter
Estimated tax, balance due and payroll depositsAccount transcript, online payment history, bank statements
Forms 941 and 940Employment tax return transcripts, which the IRS offers only for recent years; an account transcript may cover older periods

Form 7004 gives an automatic extension to file (6 months for a partnership), not to pay. The IRS no longer sends an approval and writes only if it disallows the request, and the name and EIN must match IRS records or the extension is not valid. If you cannot prove an extension was filed and the due date is close or has passed, see accountant missed the tax deadline.

If the old firm made your payroll deposits, check those first. The employer stays liable for tax, penalties and interest a third party failed to deposit. A responsible person who willfully fails to pay over withheld tax can owe it personally as the trust fund recovery penalty, generally assessable for 3 years from April 15 after the payroll year, or from a later filing date. Enroll in EFTPS under your own PIN to see deposits made in your name. See who pays the penalties.

Form 8821 or Form 2848: which does the new firm need, and who signs?

Form 8821 lets a designee see and receive your tax information. Form 2848 lets an eligible representative act for you. A new firm that will only pull transcripts can work from Form 8821. A firm that will speak to the IRS, answer a notice or request relief needs Form 2848.

Form 8821Form 2848
What it allowsInspect and receive information. It does not authorize speaking for you.Act for you in the listed matters
Who can be namedAny person or firmSomeone eligible to practice before the IRS, such as a CPA, enrolled agent or attorney
Corporation signsAn officer who can bind it, a person the board designates, and certain othersAn officer with legal authority to bind it, with exact title
Partnership signsAnyone who was a partner during part of each year the form listsAll partners, or one partner with authority under state law, with that authority attached. For a matter under the centralized partnership audit regime (an IRS audit of the partnership), the partnership representative signs.
What to listEach tax form and each year or period. A sole proprietor lists Form 1040, plus Form 941 or 940 with payrollSame. For a partnership or S corporation, "Income including pass-through items," the form number and the year
Earlier formsEarlier Form 8821s are revoked unless you attach themEarlier recorded 2848s for the same matters are generally replaced; a Form 8821 stays in effect

Do not write "All years." The IRS returns a form with a general reference. It will not record future periods beyond 3 years after December 31 of the year it receives the form. An electronic signature requires online submission at IRS.gov/Submit8821 or IRS.gov/Submit2848; a form sent by mail or fax needs a handwritten signature.

With either form on file, a CPA or other practitioner can request your transcripts through the IRS Transcript Delivery System. An unenrolled return preparer can represent you only in narrow cases, such as an examination of a return that preparer prepared and signed. Anyone not eligible to practice before the IRS can be named only on Form 8821.

How do I end the old accountant's access to my IRS account?

Revoke the old authorization in writing, and do not assume a new form does it. A new Form 2848 generally replaces earlier recorded powers of attorney for the same matters but leaves any Form 8821 in effect. A new Form 8821 revokes earlier tax information authorizations; its instructions do not say it removes a Form 2848. If the old firm held both, revoke both.

Two more authorizations can outlast both forms. If the old firm acted as your payroll reporting agent, it holds a Form 8655: neither form above ends it, and a new reporting agent's Form 8655 ends it only from the new start period, so revoke it with the steps below. A "Yes" in the paid preparer box on the last return lets that preparer call the IRS about the return's processing, and it ends by itself no later than the next return's original due date (Form 1065 instructions).

To revoke without naming anyone new:

  1. Write REVOKE across the top of a copy of the old form (the first page, for Form 2848).
  2. Sign and date it: under the original signature on Form 8821 or Form 8655, just below REVOKE on Form 2848.
  3. Mail or fax it to the IRS office listed in the form's Where To File chart.

Without a copy, send a signed statement that the authority is revoked, with the name and address of each designee and either the matters and years or periods or "revoke all years/periods" to end it fully. A specific-use authorization goes to the IRS office handling that matter.

Also check the business profile in your business tax account to review who has been given access as a Designated User. Then list every account the old accountant set up or can reach: the accounting company file, bank and card connections, payroll provider, tax payment accounts and payment processors. Once you hold a backup of the company file and know who runs payroll deposits, change the passwords and make yourself the owner or administrator of each. If the company file is under the accountant's own subscription and they will not transfer it, ask for a backup you can restore, or start a new file at your cutoff date.

When do I update my address or responsible party?

Update the address on file when the old accountant stops being the person who should get your mail, and report a new responsible party (the person who ultimately owns or controls the entity) within 60 days. Use Form 8822-B, which covers the business mailing address, location and responsible party.

The form's instructions let a business receive mail "in care of" a third party such as an accountant, but the IRS strongly suggests that an employer not use a payroll provider's address as its address of record. If you fail to give the IRS a current address, you may not receive a notice of deficiency or a notice of demand, and penalties and interest keep accruing on any deficiency. An address typed on Form 7004 does not update your record.

An officer, owner, general partner or LLC member manager signs. A new firm can sign for you only with a copy of a power of attorney, such as Form 2848, attached. Processing generally takes 4 to 6 weeks. The IRS will not make the change at the request of an unauthorized third party.

How do I rebuild the books without counting anything twice?

Pick one cutoff date, keep the old books as they stand up to it, and enter every statement line after it exactly once. Except in a few cases, the law does not require any specific kind of records. Your books must show gross income, deductions and credits, and be backed by supporting documents.

  1. Choose the cutoff. A common choice is the last month-end where the old books agree with the bank and with the last filed return. Do not re-enter anything before it.
  2. Set opening balances at the cutoff from the filed return's balance sheet (Schedule L), if it has one, and the reconciled bank balances. A Schedule C has no balance sheet, and many small partnerships and S corporations are not required to complete Schedule L. See opening balances after changing accountants for what to use then.
  3. Collect statements for every bank, card and payment account from the cutoff to today. A statement can prove a payment if it shows the amount, payee and posting or transaction date, and the check number for a check. Proof of payment alone does not establish a deduction, so keep invoices too.
  4. Enter each line once. The usual double counts:
TrapWhy it counts twiceWhat to do
Old and new files both pull the bank feedThe same deposits arrive in bothDisconnect the old feed at the cutoff
Paying a card bill from checkingCharges are expenses, then the payment is counted againCount the purchases; record the payment as a transfer
Moving money between your own accountsOne side looks like income, the other like an expenseRecord one transfer
An invoice, then its depositIncome is recorded at billing and again when paidMatch the deposit to the invoice
  1. Reconcile each account to its statement, then compare each year's totals to the transcripts and to any Forms 1099 you received. For Forms 1099 issued under your Social Security number, a wage and income transcript lists what the IRS received.

With no usable books at all, see rebuilding books from bank statements.

What if returns were never filed, or a notice is already open?

An open notice or an unfiled year usually comes before the books, because a response date or a filing runs on its own clock. Which comes first depends on the facts. The IRS says that if a notice asks for a response, act by the due date.

Late-filing penalties for a partnership or S corporation run per owner for each month a return is late, and a C corporation's run as a share of the unpaid tax. The amount depends on the year the return was due, and reasonable cause or other relief may apply: see late filing and payment penalties.

Transcripts show which years are missing. Then the books are rebuilt one year at a time, oldest first, from the last filed return. For the order of filing, see catching up on unfiled business returns. For a notice already in hand, see an IRS notice to your business.

Where do I complain, and what credentials should the next professional have?

Misconduct by a paid preparer goes to the IRS, and a CPA's conduct goes to the state board.

  • IRS. The complaint page lists, among others, not returning a client's original records, agreeing to file and not filing, filing without the client's consent, engaging in a fee dispute or threatening behavior, and failing to remit or prepare employment tax returns. The separate Form 14157-A account-change route is for Form 1040 filers; business accounts are not eligible.
  • State board. A state board of accountancy disciplines the CPAs it licenses. The Texas board, for example, generally has no jurisdiction over an unlicensed bookkeeper and treats fee disputes as outside its authority. Other states differ.

On credentials, the IRS says anyone with a PTIN can prepare returns, and skills differ. Its directory lists preparers who hold credentials the IRS recognizes or an annual filing season record of completion. For years of returns, notices or an entity with several owners, ask whether the person is a CPA, enrolled agent or attorney who can be named on Form 2848, and check a CPA's license with the state board.

Example

These examples are illustrative. Amounts are in US dollars.

Two-member LLC taxed as a partnership

A calendar-year two-member LLC has US$180,000 of revenue. Its accountant stopped answering in February. A managing partner registers for a business tax account as Designated Official, and the transcripts show no Form 1065 yet and no extension (code 460). The old firm cannot produce a Form 7004 acknowledgment, so no extension is proven. If time allows, the new firm files Form 7004 before March 15, then ties the old books for the year just ended to the bank statements and the prior year's filed return. If they tie, December 31 is the cutoff; if not, the cutoff moves back to the last month-end that ties.

S corporation with three unfiled years

An S corporation with an accepted S election, three shareholders and about US$450,000 of revenue a year never filed Form 1120-S for three years. Transcripts show a return for Year 1, none for Years 2 to 4, and an open notice about Year 2.

  • First: the notice's response date is checked, and the new firm files Form 2848 for the 1120-S years.
  • Year 2: books rebuilt from bank statements, starting from Year 1's filed balance sheet.
  • Year 3: opens with Year 2's closing balances.
  • Year 4: opens with Year 3's closing balances. The order of filing is in catching up on unfiled business returns.

Sole proprietor with only bank statements

A sole proprietor fires a bookkeeper and has only bank statements. The last month the old books reconcile is June, so the cutoff is June 30. Every statement line from July 1 is entered once. A US$4,000 July 3 deposit pays a June invoice that the old books already list, so it is matched to that invoice, not entered as new income. A deposit with no invoice in the old books is new income. The old bank feed is disconnected.

Bookkeeping

Old accountant gone, and unsure what was filed?

If your accountant went silent, a due date is close or passed, or you cannot tell which returns and payments were filed, we can take over the bookkeeping and rebuild the books. The first call covers your situation and the scope of the books, returns and forms involved.

  • Bank and card statements since the last books you trust, plus any files or logins the old accountant sent.
  • Your last filed return, and every IRS letter or notice with its date.

Free · 15 minutes

Discuss taking over

Bookkeeping

Different for you?

Figures on this page

FigureValueSource
Calendar-year partnership and S corporation ordinary federal filing deadline
Following year-end; weekend and holiday adjustments and qualifying overseas-books exceptions can change the date.
March 15IRS: Instructions for Form 1065
Checked
Calendar-year partnership and S corporation extended federal filing deadline
Following year-end with a timely Form 7004; derived from the six-month filing extension. Does not extend payment.
September 15IRS: Instructions for Form 7004
Checked
Calendar-year C corporation Form 1120 due date
Generally the 15th day of the fourth month after the tax year; weekends, holidays, and extensions can shift the filing date
April 15 of the following yearIRS: Instructions for Form 1120
Checked
Calendar-year C corporation extended Form 1120 filing date
For a calendar-year 2026 domestic C corporation with a timely, valid Form 7004 extension, the return is due October 15, 2027. Form 7004 does not extend payment time; weekend and holiday rules can move the date in other years.
October 15
Tax year 2026
IRS: Instructions for Form 7004
Checked
Ordinary calendar-year Form 1040 deadline
Following the tax year; weekends, legal holidays and special taxpayer rules can shift the date.
April 15IRS: Ordinary calendar-year Form 1040 deadline
Checked
Regular calendar-year individual filing deadline with a timely automatic extension
Following the tax year; weekend, holiday, overseas and disaster rules can alter the applicable deadline.
October 15IRS: Get an extension to file your tax return
Checked
Form 941 quarterly filing deadline
Normally April 30, July 31, October 31 and January 31; next-business-day and timely-deposit extensions may apply
The last day of the first month after each quarterIRS: Instructions for Form 941
Checked
Texas CPA deadline to return a client's original documents on request
Original documents the client supplied; no fee, even if the client has not paid. One state's rule; each state board of accountancy sets its own.
10 business daysTexas State Board of Public Accountancy: CPA firms FAQ
Checked
How far back a Form 4506-T return transcript or record of account reaches
Form 4506-T line 6a: return transcripts are available for the current year and returns processed during the prior 3 processing years; line 6c: record of account, current year and 3 prior tax years. Account transcripts (line 6b) are available for most returns.
The current year and 3 prior yearsIRS: Form 4506-T, Request for Transcript of Tax Return
Checked
Wait after e-filing before requesting a business tax transcript
For a return filed electronically; "No record of return filed" may mean the return is not processed yet.
2 to 3 weeksIRS: Get a business tax transcript
Checked
Wait after mailing a paper return before requesting a business tax transcript
For a return filed on paper.
6 to 8 weeksIRS: Get a business tax transcript
Checked
Processing time for most Form 4506-T transcript requests
The form must reach the IRS within 120 days of the signature date.
10 business daysIRS: Form 4506-T, Request for Transcript of Tax Return
Checked
IRS fee for a photocopy of a filed tax return (Form 4506)
Per return requested; full payment must be included or the request is rejected; refunded if the IRS cannot find the return.
$30IRS: Form 4506 (Rev. 4-2025), line 8
Checked
Longest stated processing time for a Form 4506 copy of a return
The form says it may take up to this long to process the request.
75 calendar daysIRS: Form 4506, Request for Copy of Tax Return (Rev. 4-2025)
Checked
General Form 7004 partnership filing extension
Timely valid extension of filing, not payment.
6 monthsIRS: Instructions for Form 7004
Checked
General trust fund recovery penalty assessment period
From the succeeding April 15 for timely employment tax returns, or actual later filing; exceptions apply
3 yearsIRS: Trust fund recovery penalty assessment period
Checked
Deemed annual employment-tax return filing date for assessment
In the succeeding calendar year; actual later return filing starts the assessment period later; exceptions can suspend or eliminate the limit
April 15IRS: Trust fund recovery penalty assessment rules
Checked
Furthest future period the IRS records on Form 8821 or Form 2848
Counted from December 31 of the year the IRS receives the form; later periods listed are not recorded.
3 yearsIRS: Instructions for Form 8821, line 3
Checked
IRS responsible-party change notice deadline
Time to report a change in a business's responsible party on Form 8822-B.
60 daysIRS: About Form 8822-B
Checked
Usual processing time for a Form 8822-B address or responsible-party change
The form's instructions say it generally takes this long to process a change.
4 to 6 weeksIRS: Form 8822-B, Change of Address or Responsible Party, Business (Rev. 12-2019)
Checked

Primary sources

About this guide

Published by Cloud Accounting under standing professional approval. This version has no separately recorded personal review. It explains general rules for the tax year shown. It is not advice for your situation.

Changes

  • : First published.
Di Lu, CPA
Di Lu, CPAUS and Canadian CPA

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