In my most recent Annual Report to Congress, I published a study in support of the Service Priorities Project (SPP), a joint effort between Taxpayer Advocate Service (TAS) and IRS Wage & Investment (W&I). The goal of the SPP is to produce a matrix to help the IRS identify where to allocate its taxpayer service resources. To assist the IRS in determining service priorities, the matrix presents data on taxpayer needs and preferences as well as more traditional IRS “efficiency” concerns. While W&I initially worked with TAS in the development of the SPP, ultimately I felt that the additions to the Taxpayer Experience Survey did not address the missing data needed to complete the SPP matrix. I directed TAS Research to develop a study and fill in the gaps of the SPP. The result, A Further Exploration of Taxpayers’ Varying Abilities and Attitudes Toward IRS Options for Fulfilling Common Taxpayer Needs, revealed several areas that I’d like to highlight today. Read More
Each year the IRS sponsors the Nationwide Tax Forums, a three-day series of tax education and networking conferences for tax professionals in cities around the country. These events feature the latest information from the IRS, news about tax law changes, the chance to meet with software vendors, and the opportunity to attend nearly 50 seminars presented by IRS employees and members of professional associations.
At this year’s Forums, Taxpayer Advocate Service (TAS) will present a series of seminars, oversee the Case Resolution Program, and host two focus groups. TAS’s seminars include: Read More
The IRS has been increasing user fees to fund its operations. It recently increased or proposed to increase a wide range of fees including the fees for installment agreements (IAs), offers-in-compromise (OICs), pre-filing agreements (PFAs), private letter rulings (PLRs), and special enrollment examinations (SEE). I raised concerns about these increases in my 2015 and 2017 Annual Reports to Congress.
On Feb. 9, 2018, Congress enacted the Bipartisan Budget Act of 2018 (P.L. 115-123), which addresses concerns about the IRS’s largest fee revenue generator – the IA fee increases. The law prevents the IRS from increasing the IA fee again without legislation. It also requires the IRS to waive or refund the fee for taxpayers with income below 250 percent of the federal poverty level who authorize the IRS to directly debit the IA payments (DDIA) from a bank account or who cannot set up a DDIA (e.g., because they do not have a bank account). This legislation suggests that Congress shares some of my concerns. This blog summarizes our concerns. Read More
In the first blog in this series we discussed how those who participate in amnesties also tend to be people who made inadvertent errors, that is, “benign” actors, rather than bad actors. We discussed how it can make sense to offer some form of amnesty before implementing a sudden increase in penalties or enforcement. Otherwise, the increase is more likely to be viewed as unfair and erode trust for the government. Moreover, a decline in trust can erode voluntary compliance.
In the second blog, we cited data showing that, consistent with the research on amnesties, IRS’s first amnesty alternative – the Offshore Voluntary Compliance Initiative (OVCI) – generally attracted people who failed to report offshore accounts but had paid their taxes or had under-reported small amounts. Read More
In last week’s blog, we discussed how broad amnesties can blunt economic deterrence, but narrow amnesties or amnesty alternatives (e.g., amnesties that forgive only penalties before noncompliance is detected) do not necessarily have the same negative effects. We also cited research suggesting that those who participate in amnesties also tend to be people who made inadvertent errors (i.e., “benign” actors, rather than bad actors). Furthermore, without an amnesty, a sudden increase in penalties or enforcement is more likely to be viewed as unfair and erode trust for the government – a view that can erode voluntary compliance. Read More
On March 13, 2018, the IRS announced that on September 28, 2018, it would end the offshore voluntary disclosure program (OVDP), as it had only attracted 600 applicants in 2017. So now is a good time to take a step back to review the program in the broader context of the research on tax amnesties.
Settlement programs and other voluntary disclosure or correction programs generally offer some form of amnesty. Offering broad tax amnesties on a regular basis, as many states do, can erode voluntary compliance. Read More
In last week’s blog, Telephone Service in an Omnichannel Environment – The IRS Must Make Communicating with the IRS Over the Phone Easier for Taxpayers, I discussed some of the struggles taxpayers will face during filing season while trying to get help from the IRS over the phone. Given the challenges of increased call volume and confusion over the tax law changes, along with the uncertainty of the IRS’s final funding level for Fiscal Years 2018 and 2019, the IRS has projected its “level of service” (LOS) on its Accounts Management lines will be anywhere from 40 percent to 80 percent for Filing Season (FS) 2018. In a later blog, I will discuss my concerns about how the IRS calculates LOS and whether that measure provides accurate information about callers’ experience with the phones. Read More
Jan. 29th marked the start of the 2018 tax filing season, as the IRS began accepting and processing an estimated 155 million individual tax returns for Tax Year 2017. Taxpayers have between now and April 17, 2018 to file their individual tax returns with the IRS, either online or through the mail, or obtain a filing extension until Oct. 15th. Filing season can be stressful for taxpayers in the best of times, as many have questions about how to properly report their earnings, claim deductions, and comply with their tax obligations. Read More
Last week, we issued the National Taxpayer Advocate’s annual report to Congress. As some of you probably noticed, we also issued the first-ever edition of the National Taxpayer Advocate “Purple Book.” In this week’s blog, I will explain why we developed the Purple Book and what it’s intended to accomplish.
Section 7803(c)(2)(B) of the Internal Revenue Code requires the National Taxpayer Advocate to issue an annual report to Congress that, among other things, proposes legislative recommendations to resolve systemic taxpayer problems. Read More
The mid-year report of the IRS National Taxpayer Advocate, Nina Olson, addresses several key problem areas with special note on challenges for the IRS and a special supplement on the recent 501(c)(4) controversy. Her observations on the IRS seem spot on to me. She states:
“Over the last few months, the Internal Revenue Service has been the center of public attention for several reasons, most notably its scrutiny of politically active social welfare organizations seeking recognition as tax-exempt entities. The public attention to these recent events has in many ways reinforced many taxpayers’ preconceived perceptions of the IRS as an agency that treats taxpayers unfairly. While all this is grievous enough and in fact calamitous for public respect for and compliance with the tax laws (because once lost, trust takes a very long time to be regained), these events are symptoms of broader problems festering at the IRS.”
“There is much that is good about the IRS – indeed, the National Taxpayer Advocate (NTA) has the deepest respect for the agency and its workforce, even when she vigorously disagrees with the IRS’s actions or policies. But today, the IRS is an institution in crisis. In the NTA’s view, however, the real crisis is not the one generating headlines. The real crisis facing the IRS – and therefore taxpayers – is a radically transformed mission coupled with inadequate funding to accomplish that mission. As a consequence of this crisis, the IRS gives limited consideration to taxpayer rights or fundamental tax administration principles as it struggles to get its job done.” Read More