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MSP #10: COMPLEXITY

The IRS Has No Process to Ensure Front-line Technical Experts Discuss Legislation with the Tax-writing Committees as Requested by Congress

TAS Recommendations and IRS Responses

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TAS RECOMMENDATION #10-1

Establish a process to automatically provide the tax writing committee staff with a list of specific front-line technical experts who can discuss the administrability of pending (or existing) legislation directly with the tax-writing committees, as provided by RRA 98, without waiting for a specific request from the tax-writing committees.

IRS RESPONSE TO RECOMMENDATION: Legislative Affairs reaches out to the Legislative Liaisons (LLs) of the BODs /FDs when Congress asks for comments on pending legislation.  In responding to these inquiries, the LLs solicit input from various levels of IRS, including technical experts.  These technical experts are analysts, technical advisors, and/or managers who were promoted to these positions from front-line jobs due to their expertise and whose jobs are to use their technical expertise in their field and front-line experience to provide instruction to front-line employees as well as gauge administrability and implement formal guidance and law changes.  Legislative Affairs reviews all comments received from the BODs/FDs and provides the response to Congress.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The IRS response suggests when Congress requests comments from the IRS on pending legislation, the LLs may solicit the views of IRS employees who were promoted from positions as front-line technical experts.  While such a process may be helpful to Congress, it is not as proactive as automatically providing the tax writing committee staff with a list of specific front-line technical experts who can discuss the administrability of pending (or existing) legislation directly with the tax-writing committees, as recommended by the National Taxpayer Advocate, without waiting for a specific request from the tax writing committees.  The IRS’s procedure does not empower the staff in Congress to hear directly from front-line technical experts, as provided by law, or to encourage them to communicate with the IRS’s experts proactively, before they have drafted legislation.  The National Taxpayer Advocate understands the IRS’s concern that the appropriate technical experts be made available to Congress; nothing in her recommendation would eliminate the IRS’s authority or ability to select which experts it makes available to Congress.  But on occasion after occasion, Congress, IRS employees, and taxpayers can point to laws that would have benefitted from the expertise and practical knowledge of these front-line technical experts, who interact with taxpayers on a daily basis and understand what aspects of law can promote or hinder taxpayer’s ability to comply.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Not Adopted

OPEN or CLOSED: Closed

DUE DATE FOR ACTION (if left open): N/A

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