irs: let the sun shine in … and out

we need clear answers, not just an info dump.

by 卡塔尔世界杯常规比赛时间 research

could the internal revenue service be a little more transparent?

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national taxpayer advocate erin m. collins thinks so, and her reasons go beyond mere functionality.

in her annual report to congress, a critique of the irs’s most serious problems, collins wrote, “any failure of the irs to fully embrace providing access and transparency risks eroding the public’s confidence in the irs, thereby threatening the bedrock principle upon which tax administration is based – taxpayers voluntarily complying through self-assessment.”

collins is questioning four essential areas of transparency:

  1. the irs reporting how it invests funding and improves service
  2. the irs reporting the status of returns being processed
  3. the irs reporting on the reliability of its guidance
  4. the irs reporting on new and upcoming guidance

inflation reduction act funding

the irs is scheduled to receive tens of billions in new funding over the next decade from the inflation reduction act. for taxpayers, practitioners, watchdogs and other stakeholders to have confidence in irs operations, collins says, they need to know how the irs is spending these funds. they have such questions as:

  • are the funds being spent appropriately, with proper priorities?
  • are there performance metrics to measure successes?
  • will the funds effect a substantial transformation of the irs?
  • how will the funds affect irs objectives and milestones?
  • are the funds being spent fairly, efficiently and equitably?

collins wants to see an open, public, living document that presents an operational plan as it changes over time.

transparency of status

over the past several years, millions of taxpayers have suffered delays in return processing and refunds. many are somewhere between anxious and infuriated as they see their returns disappear into the dark hole of the irs, there to remain for months with no explanation of the delays.

in 2022, taxpayers accessed the online where’s my refund tool 557.2 million times and where’s my amended return? 20.8 million times. these are nice tools, except that answers are all but useless. it’s either “return received,” return approved” or “refund sent.”

the information taxpayers and practitioners really need is in the gaps between those vague answers.

  • if a paper return is received, is it sitting in one of the many stacks on one of the many skids in one of the many shipping containers where the irs stores its backlog?
  • if there’s a problem with a return, well, what’s the problem?
  • if an error has been corrected, well, what’s the correction?
  • if the return has been approved, well, where’s the refund?

the irs has made a few improvements to the where’s my refund tool, but it still can’t give a taxpayer an explanation of delays or an estimate of future progress. improvements have been proposed, but implementation is contingent on funding.

imagine a dashboard

collins has suggested that the irs develop an online dashboard where taxpayers and other stakeholders can monitor overall progress on the processing of returns. taxpayers and practitioners might be more comfortable if they could see that progress is happening, even if only in general numbers. oversight organizations would be able to monitor the national status and demand explanations.

imagine answers

the irs has been very generous with information. taxpayers and practitioners have access to 41,000 webpages of guidance that would be useful to anyone who can navigate to the answer they are looking for. because each irs operating division generates its own set of webpages, there is much duplication of information – not all of it consistent, not all of it user-friendly, not all of it interlinked, and the information isn’t even complete.

reading through 41,000 webpages can be exhausting, frustrating and fruitless. erin collins says taxpayers might have an easier time of it if a reasonably intelligent chatbot could help them navigate to the answer they’re looking for. the technology exists. it just doesn’t exist at the irs.

imagine reliable guidance

assuming a taxpayer has gone through all 41,000 webpages and read the 2,500 pages of the u.s. tax code and at least flipped through the 75,000 pages of associated rules, regulations, opinions and guidance, can the taxpayer have confidence in the reliability of what what he or she has gleaned?

nope.

most irs guidance, such as instruction publications, and frequently asked questions, is considered “informal.” reliance on that information might stand as a defense when a return is questioned, but then again, it might not.

internal revenue bulletins are considered “formal” and can be relied on in an audit or penalty relief situation.

many irs publications, however, are of unclear reliability. nothing in most publications specifies reliability.

collins sees a lot of room for improvement here.

  • the various operations divisions could share one set of webpages.
  • duplication could be eliminated.
  • reliability could be indicated on every page or document.

imagine foreseeing changes

the irs is constantly updating its rules, regulations, notices, rulings and procedures. these changes don’t happen overnight. they develop over time. wouldn’t it be nice if taxpayers – and, especially, tax practitioners – could readily see what’s coming down the pike and when it’s expected to arrive?

all of the above is feasible. the technology exists. the funding is on the way. let’s hope we can see and comment on how it’s spent.