Want to improve the IRS?®SPEAK
By Andrea Price, Taxpayer Advocacy Panel member representing
Most Serious Issues Facing Taxpayers
In December 2018, the National Taxpayer Advocate identified
the Most Serious Problems facing taxpayers and made
recommendations for addressing them in the Annual Report to
Congress (ARC). In June 2019, the National Taxpayer Advocate
submitted the Objectives Report to Congress, which included
a second volume that contains the IRSís responses to their
recommendations together with their analysis of the IRSís
The National Taxpayer Advocate believes it is important for
taxpayers, tax practitioners, and Members of Congress to see
how the IRS responded, and below are a few examples of IRSís
responses and related analysis.
Most Serious Problem 1 - Tax Law Questions: The IRS has agreed
to study the feasibility of returning to its previous
practice of answering in-scope tax law questions
year-round on the phones.
Most Serious Problem 2 - Chief Counsel Transparency: IRS Counsel
has agreed to clarify the standards that should be
considered when deciding whether legal advice should be
issued in a formal memorandum.
Most Serious Problem 4 - Free File: The IRS has agreed to make
numerous improvements to the Free File program,
including evaluating ways to expand the program for
English as second language taxpayers.
Most Serious Problem 5 - False Positive Rate: The IRS has agreed
to take steps to evaluate the effectiveness of its fraud
detection systems (and their associated high false
positive rates) and to collaborate with Taxpayer
Service (TAS) on a study
analyzing why some taxpayers delay responding to IRS
Most Serious Problem 9 - Field Examination and Most
Serious Problem 10 Ė Office Examination: For
these two problems, the IRS continues to disagree that
it needs to more carefully track what happens after an
audit, including whether the taxpayer appeals and
maintains future compliance, to better refine its audit
selection process and maximize limited resources.
Most Serious Problem 11 - Post Processing Math Error and
Most Serious Problem 12 Ė Math Error Notices: The
IRS has declined to adopt a policy to limit its use of
math error authority to circumstances least likely to
burden taxpayers or waste IRS resources. While it did
agree to implement some of TASís recommended changes to
improve math error notice clarity, the IRS has not
adopted TASís recommendations to improve the efficiency
of math errors and protect taxpayer rights.
Most Serious Problem 13 - Statutory Notices of
IRS has agreed to include specific TAS office
information in statutory notices of deficiency.
Most Serious Problem 15 - Economic Hardship: While the IRS has
implemented certain safeguards for taxpayers
experiencing economic hardship, it has not agreed to
implement a systemic economic hardship indicator that
would identify taxpayers who have incomes lower than
their allowable living expenses and no detectable
assets. We recommended the IRS implement an economic
hardship indicator to help ensure it doesnít collect
from low income taxpayers under circumstances that would
leave them without adequate means to provide for their
basic living expenses.
For those interested in more detail on the IRSís full
responses to all 20 Most Serious Problems identified in
the Annual Report to Congress, I encourage you to read
this yearís Volume
2 included in the Fiscal
Year 2020 Objectives Report to Congress.
Go to taxpayeradvocate.irs.gov.
Taxpayer Advocacy Panelís (TAP) mission is to listen to
taxpayers, identify taxpayersí issues and make suggestions
for improving the IRS service and customer satisfaction. We
not only listen to taxpayers; we try to do something about
it. TAP is supported by and aligned with the IRS but is not
part of the IRS and are not employees of the IRS. TAP is
comprised of civic-minded citizen volunteers from all
walks of life representing each state, D.C., Puerto Rico and
an international member (citizens living, working or doing
Everyone has something to say about taxes and the IRS. Please take a
moment to give us your suggestions for TAP to consider by
contacting one of the following:
TAP Ohio member: