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MSP #10: TAXPAYER ASSISTANCE CENTERS (TACS)

Cuts to IRS Walk-In Sites Have Left the IRS With a Substantially Reduced Community Presence and Have Impaired the Ability of Taxpayers to Receive In-Person Assistance

TAS Recommendations and IRS Responses

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1.

TAS RECOMMENDATION #10-1

Institute a dual appointment and walk-in structure at TACs at the taxpayer’s choice.

IRS RESPONSE TO RECOMMENDATION: Appointment procedures include same day appointments and management-approved exception appointments for taxpayers who walk-in.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The National Taxpayer Advocate is pleased with this change to the appointment service at TACs, however, she does not believe the IRS has actually implemented this recommendation. Serving taxpayers who arrive without appointments reduces the burden on taxpayers from having to return to receive assistance at a later date. As discussed above, the current TAC signage literally belies the IRS’s stated intent that it will accept walk-ins on all issues. Therefore, the National Taxpayer Advocate strongly urges the IRS to adjust the signs at the TACs to reflect this change in policy as the sign still reflects “Appointments Required” as the main language and shows no indication that a taxpayer could walk in and potentially get an appointment immediately. The signs should read along the lines of “Appointments Recommended, but Walk-ins Are Welcome.”

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Partially Adopted

OPEN or CLOSED: Closed

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

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2.

TAS RECOMMENDATION #10-2

Request the funding for, and in consultation with TAS, develop a pilot mobile van program.

IRS RESPONSE TO RECOMMENDATION: The IRS has tested this option in the past and received low taxpayer interest and turnout. For example, the IRS conducted a mobile Tax Tour in North Dakota using alternative locations. Despite efforts to promote the IRS’s availability in the mobile locations through radio announcements, newspaper ads, and local flyers, the number of taxpayers served was 76 in 2008, 12 in 2009, and 13 in 2010. Based on these tests, we have observed that taxpayers do not come to sites that are not established and staffed on a regular basis.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The IRS has previously provided the same response regarding its test of Tax Tours in North Dakota in response to other National Taxpayer Advocate recommendations to implement a mobile van program.3 However, as noted in a prior TAS response to this assertion, the IRS has yet to provide the National Taxpayer Advocate with details and results of the program in order to allow TAS to evaluate the program design. Successful pilots of van and co-location programs must contain several key elements. The programs must be consistent; that is, taxpayers must be able to expect that certain services will be available on certain days in certain locations. Haphazardly advertising a mobile van program through print and advertising, holding the program for one day, and then declaring it was unsuccessful because only a few taxpayers availed themselves of the service does not reflect a well-structured pilot program. It will take time for taxpayers to realize and trust that a mobile TAC will be in their area every other Thursday offering full-scale IRS services. A one-day trial, even with advertising, will not give the IRS useful information about the extent to which taxpayers use the program.

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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3.

TAS RECOMMENDATION #10-3

Answer tax law questions throughout the year, at both TACs and on the phones.

IRS RESPONSE TO RECOMMENDATION: The IRS provides guidance to taxpayers through a variety of channels year-round. Taxpayers can find tax law information 24 hours per day, seven days per week, at IRS.gov. Through IRS.gov, taxpayers have access to numerous Publications, Tax Topics, Frequently Asked Questions, and Tax Trails. Through the Interactive Tax Assistant (ITA), taxpayers can easily access various self-service options. The ITA is a very heavily used tool, thus, our goal is to annually increase the number of available ITA topics on IRS.gov to assist taxpayers with their tax law questions. Currently, there are 44 topics covered and usage for FY 2017 of the ITA tool was over 1.8 million. Tax law inquiries that are within the scope of our TACs and telephone assistors are answered from January through mid- April; in addition, such inquiries are answered all year if the question is related to the resolution of an account inquiry. Tax law assistance is provided on the telephone year-round for a number of subject areas, including Affordable Care Act, International, Tax-Exempt/Government Entities, Business Master File (Employment Tax), and Special Services (Disaster, Combat Zone, etc.).

We also intend to assist taxpayers, year-round, with the recent tax reform legislation. We are still determining how we will deliver that assistance.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The National Taxpayer Advocate is pleased that the IRS has moved disaster relief to the list of in-scope tax law topics covered year-round. She looks forward to reviewing the IRS’s plan to assist taxpayers year-round with tax law questions related to the recently enacted Tax Cuts and Jobs Act. While ITA is a promising tool for taxpayers who are internet savvy, with only 44 topics covered currently, it is not a fully robust tool. The National Taxpayer Advocate supports the IRS’s effort to continue to flesh out additional topics areas, however, taxpayer service must meet the needs of all taxpayers, not just those who are able to access internet content and apply the answer to their specific situation. As noted elsewhere in this Report, 41 million U.S. taxpayers do not have broadband in their homes, and 14 million have no internet access at all in their homes. In addition, the online ITA tool cannot substitute fully for person-to-person interaction between a taxpayer and an assistor, when a taxpayer can ask follow up questions and request clarifications.

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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4.

TAS RECOMMENDATION #10-4

Reinstate return preparation for amended disaster-based casualty loss returns.

IRS RESPONSE TO RECOMMENDATION: In 2015, the IRS implemented the Service Approach model because we recognized there was an increase in electronic filing, with fewer returns being prepared at walk-in offices each year, and a steady increase in tax returns prepared through other channels. Because of this trend, TACs no longer prepare tax returns or amended returns, and no longer maintain the tax return preparation software needed to complete original or amended returns. Taxpayers have many alternatives for free return preparation service such as Free File, which is available on IRS.gov, and other free software and local resources. Although casualty loss returns are outside the scope of the Volunteer Income Assistance and Tax Counseling for the Elderly programs, this is another alternative for free return preparation.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The National Taxpayer Advocate is perplexed by the IRS response to this recommendation. The recommendation is extremely narrow — offer tax return preparation for one category of amended returns in TACs. Yet, the IRS describes two options that taxpayers can use for free return preparation while at the same time acknowledging that neither of those options can prepare the specific type of return addressed in the recommendation. This response is not germane to the recommendation.

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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5.

TAS RECOMMENDATION #10-5

Staff TACs during peak times with co-located staff such as revenue officers or revenue agents to handle overflow and appointments.

IRS RESPONSE TO RECOMMENDATION: The Field Assistance Scheduling Tool (FAST), which was implemented in January 2018, is an upgrade from the prior appointment service scheduling tool with features that are easy to use, and which allow for a more intuitive approach to managing and scheduling taxpayer appointments. The FAST may negate the need for additional staff during peak times. Nonetheless, Field Assistance has adopted a model to collaborate with Accounts Management and Campus Compliance to staff TACs with extra resources during peak times, when required.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The National Taxpayer Advocate is pleased that the IRS has implemented FAST to streamline the appointment service and facilitate same-day appointments. The National Taxpayer Advocate urges the IRS to allow taxpayers to use FAST from their own devices to self-schedule TAC appointments at their convenience, eliminating the need for taxpayers to call the IRS for an appointment.

However, the National Taxpayer Advocate is concerned that the IRS has misconstrued the recommendation to staff TACs during busy times with co-located employees such as Revenue Officers (ROs) and Revenue Agents (RAs). While the IRS says it will utilize co-located Accounts Management and Campus Compliance staff to assist at TACs during peak times, this action will impact only a small fraction of TACs as these employees are only located in IRS Campuses and Remote Sites, of which there are 25, while there are 371 TACs. The National Taxpayer Advocate believes, that in addition to assisting additional taxpayers during peak TAC hours, ROs and RAs would benefit from directly interacting with taxpayers as they attempt to comply with the law. Understanding the full picture of a taxpayer’s situation as the taxpayer tries to comply with the law would help ROs and RAs develop empathy for the taxpayer.

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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