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MSP #2: RETURN PROCESSING

Continuing Delays in IRS Return Processing Are Frustrating Taxpayers and Causing Refund Delays

TAS Recommendations and IRS Responses

1
1.

TAS RECOMMENDATION #2-1

By the end of Fiscal Year (FY) 2025, ensure Submission Processing’s scanning technology captures the same data elements on paper returns as from e-filed returns.

IRS RESPONSE TO RECOMMENDATION: ​We will incorporate the same data elements on scanned paper returns as those captured from e-filed returns. We expect to complete implementation of this recommendation by the end of Calendar Year (CY) 2027. Any improvements or changes made will be dependent on resource availability and funding.

CORRECTIVE ACTION: We will incorporate the same data elements on scanned paper returns as those captured from e-filed returns. We expect to complete implementation of this recommendation by the end of Calendar Year (CY) 2027. Any improvements or changes made will be dependent on resource availability and funding.

TAS RESPONSE: TAS commends the IRS’s willingness to adopt this important recommendation. Completing implementation of this recommendation by the end of Calendar Year (CY) 2027 will help ensure the success of the Paperless Processing Initiative.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Partially Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): 1/1/2028

2
2.

TAS RECOMMENDATION #2-2

Conduct an analysis by the end of FY 2025 to identify the root causes of the missed Program Completion Dates and other business measure targets from Filing Seasons 2023 and 2024 and develop an action plan to meet them for the upcoming filing season.

IRS RESPONSE TO RECOMMENDATION: We will conduct an analysis to identify the root causes of missed Program Completion Dates and other business measure goals for Filing Seasons 2023 and 2024. Based on the findings, we will develop an action plan to improve performance in the upcoming filing season.

CORRECTIVE ACTION: ​We will conduct an analysis to identify the root causes of missed Program Completion Dates and other business measure goals for Filing Seasons 2023 and 2024. Based on the findings, we will develop an action plan to improve performance in the upcoming filing season.

TAS RESPONSE: TAS commends the IRS’s willingness to fully adopt this important recommendation. We look forward to reviewing the IRS’s action plan to improve performance in the upcoming filing season and will provide assistance as needed to implement the plan.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): 7/31/2025

3
3.

TAS RECOMMENDATION #2-3

Broaden business rules for e-filed returns to accept submissions where they satisfy the Beard test and direct them to an appropriate treatment stream for resolving discrepancies by FY 2027.

IRS RESPONSE TO RECOMMENDATION: We continuously review and evaluate solutions to assist taxpayers in filing complete electronic returns to alleviate delays in processing and issuance of correspondence. The e-file system rejects fraudulent or duplicate returns as agreed upon through the Security Summit. This is a collaboration between the IRS and members of private industries, the states, and financial institutions, to prevent fraud from occurring and to protect taxpayers. Additionally, the IRS works with external partners to educate them on the top error rejection codes during various industry calls. We will continue to assess specific scenarios that force taxpayers to file by paper and analyze whether we can allow them in electronically while mitigating the risk of fraudulent activity. As an example, we expanded electronic filing capabilities with a programming solution to allow Duplicate Dependent returns with an Identity Protection Personal Identification Number (IP PIN) for Filing Season 2025.

CORRECTIVE ACTION: N/A

TAS RESPONSE: TAS appreciates the IRS’s need to mitigate the risk of fraudulent activity, however there are multiple options to accomplish that goal without rejecting valid e-filed returns, especially returns requesting refunds. Because filing a tax return is also a significant trigger for determining whether the taxpayer filed the return timely, the application of penalties, and the start of assessment and refund statutes, this is an important issue. TAS will continue to gather recommendations and feedback from taxpayers and tax practitioners about potential changes that would have the greatest impact on reducing taxpayer burden.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Not Adopted

OPEN or CLOSED: Closed

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

4
4.

TAS RECOMMENDATION #2-4

Work with the Social Security Administration to integrate information return documents available in IOLA with e-filing software by FY 2027 and post it by March 1 each year.

IRS RESPONSE TO RECOMMENDATION: ​​The IRS plans to include Adjusted Gross Income and IP PIN into the e-file software in the Taxpayer Disclosure Authorization deployment in July 2025. We are planning to include Form W-2, Wage and Tax Statement, and Form 1099 information in the future. Implementation is contingent on available funding.

Implementation date: July 31, 2025 (and ongoing for future implementations)

CORRECTIVE ACTION: The IRS plans to include Adjusted Gross Income and IP PIN into the e-file software in the Taxpayer Disclosure Authorization deployment in July 2025. We are planning to include Form W-2, Wage and Tax Statement, and Form 1099 information in the future. Implementation is contingent on available funding.

TAS RESPONSE: TAS commends the IRS’s willingness to partially adopt this important recommendation. Including Adjusted Gross Income and IP PIN into the e-file software in the Taxpayer Disclosure Authorization will be a positive step for taxpayers. The IRS should prioritize further upgrades that include Form W-2, Wage and Tax Statement, and Form 1099 information as soon as funding becomes available.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Partially Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): 7/31/2025

5
5.

TAS RECOMMENDATION #2-5

Add capabilities that allow taxpayers to respond to notices and letters, including uploading documents within IOLA by (or in) FY 2026, and within TaxPro Account and Business Online Account by FY 2027.

IRS RESPONSE TO RECOMMENDATION: ​​In February 2025, we deployed the ability in Individual Online Account (IOLA) for some taxpayers to respond to CP2000 notices with messaging and document upload. Also planned later in FY 2025 is the capability for taxpayers to upload documents for certain digital notices in IOLA. In FY 2026, we are working on expanding these messaging and document upload capabilities to more taxpayers and additional notice types.

Notably, it should not be assumed that improving the ability for taxpayers to respond to notices and letters online with have a direct, short-term, positive impact on return processing timelines or refund delays. However, it is a good idea to improve the user experience for responding to notices online because it is likely that this will save taxpayers time and frustration.

The IRS cannot commit to the proposed timeline, due to the complexities of existing foundational technology systems and business processes that need to be modified in order to scale this feature across all possible notice and document types. However, we do intend to design a scalable document ingestion/storage/routing platform for digital document upload in relation to taxpayer notices (may or may not be online account(s)). We will provide updates, including a realistic time-based roadmap, as that design becomes available.

CORRECTIVE ACTION: The IRS cannot commit to the proposed timeline, due to the complexities of existing foundational technology systems and business processes that need to be modified in order to scale this feature across all possible notice and document types. However, we do intend to design a scalable document ingestion/storage/routing platform for digital document upload in relation to taxpayer notices (may or may not be online account(s)). We will provide updates, including a realistic time-based roadmap, as that design becomes available.

TAS RESPONSE: TAS commends the IRS’s willingness to partially adopt this important recommendation. The IRS notes that improving the ability for taxpayers to respond to notices and letters online will not have a direct, short-term, positive impact on return processing timelines or refund delays, however the resources required to process paper correspondence diminish the resources that could be devoted to processing paper returns. Allowing taxpayers to receive and respond to all notices online will place the IRS on par with major tax administrations worldwide.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Partially Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): Ongoing

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6.

TAS RECOMMENDATION #2-6

Upgrade the Where’s My Amended Return? tool to allow international taxpayers to use it for any pending amended returns by FY 2026.

IRS RESPONSE TO RECOMMENDATION: ​​The IRS intends to implement this tool enhancement but is unable to commit to the FY 2026 timeframe. The IRS continues to consider this request among all prioritized enhancement and critical maintenance resource needs — dependent on resources and funding.

CORRECTIVE ACTION: The IRS intends to implement this tool enhancement but is unable to commit to the FY 2026 timeframe. The IRS continues to consider this request among all prioritized enhancement and critical maintenance resource needs — dependent on resources and funding.

TAS RESPONSE: TAS commends the IRS’s willingness to adopt this important recommendation. International taxpayers face barriers to compliance and need access to the same tools enjoyed by domestic taxpayers.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Partially Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): Ongoing

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7.

TAS RECOMMENDATION #2-7

Revise Form 1040 to add a box indicating it is an amended return and allow taxpayers to file it electronically by FY 2027.

IRS RESPONSE TO RECOMMENDATION:We are currently evaluating an option to streamline the form-based intake of individual returns using a Form 1040 with an amendment checkbox rather than using or including a Form 1040X. Implementation is contingent on findings and available funding.

CORRECTIVE ACTION: We are currently evaluating an option to streamline the form-based intake of individual returns using a Form 1040 with an amendment checkbox rather than using or including a Form 1040X. Implementation is contingent on findings and available funding.

TAS RESPONSE: TAS commends the IRS’s willingness to partially adopt this important recommendation. Streamlining the form-based intake of individual returns using a Form 1040 with an amendment checkbox would revolutionize amended returns processing, reduce taxpayer burden, and would also allow the IRS to dedicate more resources to improving telephone service, as many employees must currently split their time between working amended returns inventory and answering calls for customer service.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Partially Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): 9/30/2027