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Home > Reports > 2025 Annual Report to Congress > Full Report 2025

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Full Report

The National Taxpayer Advocate’s Annual Report to Congress identifies taxpayers’ problems and provides suggestions to further protect taxpayer rights and ease taxpayer burden.

Full Report

5.95 MB

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Executive Summary

3.65 MB

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Purple Book

9.40 MB

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News Room

392.07 KB

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Report Contents

Full Downloads & Executive Summary

2025 Annual Report to Congress

Preface

  1. Introductory Remarks by the National Taxpayer Advocate
  2. Taxpayer Rights and Service Assessment: IRS Performance Measures and Data Relating to Taxpayer Rights and Service

The Most Serious Problems Encountered by Taxpayers

Introduction

  1. AMENDED RETURNS: Refund Delays and Unclear and Confusing Disallowance Notices Harm Taxpayers and Jeopardize Their Rights to Administrative and Judicial Review
  2. IRS MODERNIZATION AND DIGITALIZATION: Outdated Paper Processes and Procurement Delays Harm Taxpayers
  3. TELEPHONES: The IRS Does Not Accurately Measure the Quality of Telephone Service
  4. INDEPENDENT OFFICE OF APPEALS: Taxpayers and Tax Professionals Continue to Raise Concerns About Independence, Undermining Public Confidence in the Appeals Process
  5. TAX PRO ACCOUNT: Online Accounts for Tax Professionals Lack Critical Functionality Required to Effectively Represent Taxpayers
  6. RECORDS ACCESS: Taxpayers Face Delays and Inadequate Responses to Their Administrative Requests for Records From the IRS
  7. CENTRALIZED AUTHORIZATION FILE: Systemic Failures Undermine Taxpayer Rights to Representation, Due Process, and Quality Service
  8. SOCIAL MEDIA: The Negative Tax Influence of Social Media Harms Taxpayers
  9. TAXPAYERS LIVING ABROAD: U.S. Taxpayers Living Abroad Face Severe Compliance Burdens
  10. INTERNATIONAL WITHHOLDING RELIEF: Taxpayers Face Long Delays and Hardships With IRS Processes Designed to Offer Relief From International Withholding Requirements

Most Litigated Issues

TAS Advocacy

TAS Case Advocacy
TAS Systemic Advocacy
Taxpayer Advocate Directives

Appendices

Appendix 1: TAS Directory
Appendix 2: Data Compilation and Validation
Appendix 3: Glossary of Acronyms
Online only: ARC Recommendations Tracker
Online only: Fiscal Year 2025 Objectives Report to Congress: Objectives Status Update

National Taxpayer Advocate 2026 Purple Book: Compilation of Legislative Recommendations to Strengthen Taxpayer Rights and Improve Tax Administration

INTRODUCTION

STRENGTHEN TAXPAYER RIGHTS

  1. Elevate the Importance of the Taxpayer Bill of Rights by Redesignating It as Section 1 of the Internal Revenue Code
  2. Require the IRS to Timely Process Claims for Credit or Refund
  3. Require Notices of Claim Disallowance to Clearly State the Reasons for Disallowance, Explain Administrative and Judicial Appeal Options, and Specify Applicable Timeframes

IMPROVE THE FILING PROCESS

  1. Treat Electronically Submitted Tax Payments and Documents as Timely If Submitted on or Before the Applicable Deadline
  2. Authorize the IRS to Establish Minimum Standards for Federal Tax Return Preparers and to Revoke the Identification Numbers of Sanctioned Preparers
  3. Extend the Time for Small Businesses to Make Subchapter S Elections
  4. Adjust Individual Estimated Tax Payment Deadlines to Occur Quarterly
  5. Eliminate Duplicative Reporting Requirements Imposed by the Bank Secrecy Act and the Foreign Account Tax Compliance Act
  6. Authorize the Use of Volunteer Income Tax Assistance Grant Funding to Assist Taxpayers With Applications for Individual Taxpayer Identification Numbers

IMPROVE ASSESSMENT AND COLLECTION PROCEDURES

  1. Continue to Limit the IRS’s Use of “Math Error Authority” to Clear-Cut Categories Specified by Statute
  2. Require Independent Managerial Review and Written Approval Before the IRS May Assert Multiyear Bans Barring Taxpayers From Receiving Certain Tax Credits and Clarify That the Tax Court Has Jurisdiction to Review the Assertion of Multiyear Bans
  3. Give Taxpayers Abroad Additional Time to Request Abatement of a Math Error Assessment
  4. Give Taxpayers Abroad Additional Time to Request a Collection Due Process Hearing and to File a Petition Challenging a Notice of Determination in the Tax Court
  5. Provide That Assessable Penalties Are Subject to Deficiency Procedures
  6. Direct the IRS to Implement an Automated Formula to Identify and Protect Taxpayers at Risk of Economic Hardship
  7. Allow Taxpayers to Dispute an Underlying Tax Liability in a Collection Due Process Hearing If They Have Not Had a Prior Opportunity to Dispute the Liability in the U.S. Tax Court
  8. Prohibit the IRS from Withholding the Earned Income Tax Credit Portion of a Taxpayer’s Refund to Satisfy Federal Tax Liabilities
  9. Eliminate Installment Agreement User Fees for Low-Income Taxpayers and Those Paying by Direct Debit
  10. Improve Offer in Compromise Program Accessibility by Eliminating the Upfront Payment Requirements
  11. Require the IRS to Consider a Taxpayer’s Current Income When Determining Whether to Waive or Reimburse an Installment Agreement User Fee
  12. Modify the Requirement That the Office of Chief Counsel Review Certain Offers in Compromise
  13. Require the IRS to Mail Notices at Least Quarterly to Taxpayers With Delinquent Tax Liabilities
  14. Clarify When the Two-Year Period for Requesting Return of Levy Proceeds Begins So Persons Subject to Paper Levies and Persons Subject to Electronic Levies Are Similarly Treated
  15. Protect Retirement Funds From IRS Levies, Including So-Called “Voluntary” Levies, Absent Flagrant Conduct by a Taxpayer
  16. Provide Stronger Taxpayer Protections Before the IRS May Recommend the Filing of a Lien Foreclosure Suit on a Taxpayer’s Principal Residence
  17. Provide Collection Due Process Rights to Third Parties Holding Legal Title to Property Subject to IRS Collection Actions
  18. Extend the Time Limit for Taxpayers to Sue for Damages for Improper Collection Actions
  19. Revise the Private Debt Collection Rules to More Accurately Identify and Protect Taxpayers With Incomes Below 200% of the Federal Poverty Level

REFORM PENALTY AND INTEREST PROVISIONS

  1. Convert the Estimated Tax Penalty Into an Interest Provision to Properly Reflect Its Substance
  2. Apply a Single Interest Rate to Underpayments of Estimated Tax in the Periods Between Each Installment Due Date
  3. Extend the Reasonable Cause Defense for the Failure-to-File Penalty to Taxpayers Who Rely on Return Preparers to E-File Their Returns
  4. Authorize a Penalty for Tax Return Preparers Who Engage in Fraud or Misconduct by Altering a Taxpayer’s Tax Return
  5. Clarify That Supervisory Approval Is Required Under IRC § 6751(b) Before Proposing Penalties
  6. Require an Employee to Determine and a Supervisor to Approve All Negligence Penalties Under IRC § 6662(b)(1)
  7. Increase the Burden of Proof for Determining That a Failure to File a Report of Foreign Bank and Financial Accounts Was “Willful” and Reduce the Maximum Penalty Amount

STRENGTHEN TAXPAYER RIGHTS BEFORE THE OFFICE OF APPEALS

  1. Require Taxpayers’ Consent Before Allowing IRS Counsel or Compliance Personnel to Participate in Appeals Conferences

STRENGTHEN THE OFFICE OF THE TAXPAYER ADVOCATE

  1. Clarify That the National Taxpayer Advocate May Hire Legal Counsel to Enable Her to Advocate More Effectively for Taxpayers
  2. Clarify the Authority of the National Taxpayer Advocate to Make Personnel Decisions to Protect the Independence of the Office of the Taxpayer Advocate
  3. Clarify the Taxpayer Advocate Service’s Access to Files, Meetings, and Other Information
  4. Authorize the National Taxpayer Advocate to File Amicus Briefs
  5. Authorize the Office of the Taxpayer Advocate to Assist Certain Taxpayers Experiencing Economic Hardships During a Lapse in Appropriations
  6. Repeal Statute Suspension Under IRC § 7811(d) for Taxpayers Seeking Assistance From the Taxpayer Advocate Service

STRENGTHEN TAXPAYER RIGHTS IN JUDICIAL PROCEEDINGS

  1. Expand the U.S. Tax Court’s Jurisdiction to Hear Refund Cases
  2. Authorize the Tax Court to Order Refunds or Credits in Collection Due Process Proceedings Where Liability Is at Issue
  3. Promote Consistency With the Supreme Court’s Boechler Decision by Making the Time Limits for Bringing All Tax Litigation Subject to Equitable Judicial Doctrines
  4. Extend the Deadline for Taxpayers to File a Refund Suit When They Request Appeals Reconsideration of a Notice of Claim Disallowance and the IRS Has Not Timely Decided Their Claim
  5. Authorize the Tax Court to Sign Subpoenas for the Production of Records Held by a Third Party Prior to a Scheduled Hearing
  6. Provide That the Scope of Judicial Review of Innocent Spouse Determinations Under IRC § 6015 Is De Novo
  7. Clarify That Taxpayers May Raise Innocent Spouse Relief as a Defense in Collection, Bankruptcy, and Refund Cases
  8. Fix the Donut Hole in the Tax Court’s Jurisdiction to Determine Overpayments by Non-Filers With Filing Extensions

MISCELLANEOUS RECOMMENDATIONS

  1. Restructure the Earned Income Tax Credit to Make It Simpler for Taxpayers and Reduce Improper Payments
  2. Adopt a Consistent and More Modern Definition of a “Qualifying Child” Throughout the Internal Revenue Code
  3. Provide Consistent Tax Relief for Victims of Federally Declared Disasters
  4. Permanently Give Taxpayers Affected by Federally Declared Disasters the Option of Using Prior Year Earned Income to Claim the Earned Income Tax Credit
  5. Reinstate the Theft Loss Deduction So Scam Victims Are Not Taxed on Amounts Stolen From Them
  6. Amend the Lookback Period for Allowing Tax Credits or Refunds to Include the Period of Any Postponement or Additional or Disregarded Time for Timely Filing a Tax Return
  7. Protect Taxpayers in Federally Declared Disaster Areas Who Receive Filing and Payment Relief From Inaccurate and Confusing Collection Notices
  8. Allow Taxpayers to Claim the Child Tax Credit and Earned Income Tax Credit for a Child Who Meets All Statutory Requirements Except Having a Social Security Number by the Due Date for the Tax Return
  9. Allow Members of Certain Religious Sects That Do Not Participate in Social Security and Medicare to Obtain Employment Tax Refunds
  10. Remove the Requirement That Written Receipts Acknowledging Charitable Contributions Must Be “Contemporaneous”
  11. Establish a Uniform Standard Mileage Deduction Rate
  12. Encourage and Authorize Independent Contractors and Service Recipients to Enter Into Voluntary Withholding Agreements
  13. Require the IRS to Specify the Information Needed in Third-Party Contact Notices
  14. Enable the Low Income Taxpayer Clinic Program to Assist More Taxpayers in Controversies With the IRS
  15. Clarify That Late-Filed Tax Returns Qualify as “Returns” for Bankruptcy Discharge Purposes
  16. Compensate Taxpayers for “No Change” National Research Program Audits
  17. Improve Tax and Financial Literacy by Promoting Interagency Collaboration and Modernizing the Requirement That the IRS Publish Charts on Government Revenue and Outlays
  18. Establish the Position of IRS Historian Within the Internal Revenue Service to Record and Publish Its History
  19. Postpone Tax Deadlines for Hostages and Individuals Wrongly Detained Abroad
  20. Strengthen Incentives for IRS Contractors to Ensure Their Employees Keep Taxpayer Return Information Confidential
  21. Eliminate the IRS’s “Roadmap for Evading Tax Court Review” in Collection Due Process Cases

Appendix 1: Additional Reference Materials for Legislative Recommendations in This Volume

Appendix 2: Prior National Taxpayer Advocate Legislative Recommendations Enacted Into Law