In Allen Buckley and Allen Buckley LLC v. United States, a U.S. district court in the Northern District of Georgia (not yet published) granted summary judgment in favor of the Defendant, upholding an Eleventh Circuit decision that affirmed the validity of imposing a user fee to obtain a preparer tax identification number (“PTIN”). The Plaintiff had argued that there was no statutory authorization for the PTIN user fees charged by the Treasury Department. Internal Revenue Code § 6109 generally authorizes the I.R.S. to issue identifying numbers, including to tax return preparers, and provides authority for administrative regulations. In interpreting the statute, the Court found that § 6109(a)(4) authorizes Treasury to issue regulations and assess user fees for the PTIN programs, including for annual renewal fees, so long as they were not arbitrary or excessive.