September 15, 2020
Director of Public Policy and Communications
National Taxpayer Advocate (NTA) Erin M. Collins outlined various resources available to taxpayers and practitioners during the IRS’s Small Business Forum on September 15. The IRS hosted the forum in partnership with the U.S. Chamber of Commerce and the National Federation of Independent Business (NFIB). The National Society of Accountants (NSA) attended the forum on behalf of NSA members.
Taxpayer Advocate Service
“When the system is broken, we can come in and try to figure out how to fix it on behalf of the taxpayer,” Collins said of the IRS’s Taxpayer Advocate Service (TAS). TAS, an independent organization within the IRS, serves as taxpayers’ “voice at the IRS,” helping taxpayers and practitioners alike resolve issues with the agency.
Prior to Collins’ current role as the NTA, she was an attorney in the IRS Office of Chief Counsel for nearly 15 years. She subsequently spent 20 years at KPMG, where she was the managing director of the firm’s tax controversy practice for the Western region.
Notably, Collins emphasized during the forum that there are no statutory dollar limitations on TAS’s assistance. “TAS can help all taxpayers,” she said. If a taxpayer or practitioner is not hearing from the IRS, despite frequent efforts of communication, TAS can intervene, according to Collins. “I take the ‘all’ very literally – meaning we can represent almost anyone.”
TAS has close to 80 offices across the U.S., with its headquarters located in Washington, D.C.
According to Collins, TAS has four primary missions:
- Identify problems taxpayers have with the IRS;
- Identify systemic issues within the IRS;
- Identify administrative problems within the IRS and present those issues to Congress while proposing solutions for the IRS to consider; and
- Propose legislative changes to help mitigate issues taxpayers are facing.
System Advocacy Management System
In particular, Collins highlighted the importance of TAS’s Systemic Advocacy Management System, which allows taxpayers and practitioners to electronically submit issues for TAS’s review that potentially affect multiple taxpayers. Collins referred to this aspect of TAS’s work as “systemic advocacy.”
Currently, TAS has approximately “130 issues we are pressing with respect to taxpayers,” Collins told participants of the IRS forum.
Additionally, Collins spotlighted the need for more digital service options for taxpayers and practitioners as the IRS works toward information technology (IT) modernization under Section 2101 of the Taxpayer First Act (TFA) (P.L. 116-25). NSA was instrumental in the advocacy of certain IRS restructuring proposals pursuant to the TFA, which was the first IRS reform legislation enacted in over 20 years.
“My goal is for taxpayers to be able to communicate [with the IRS] electronically for everything,” Collins said during the forum. “There is always the next challenge and next disaster, and we really need people to be able to contact and get communications from the IRS electronically. In today’s environment, having things go from one computer to another computer makes a lot of sense.”
To that end, Collins told participants of the forum that it is the IRS’s goal to begin allowing practitioners to submit and view electronically Form 2848, Power of Attorney and Declaration of Representative, by year’s end. Meanwhile, Collins’ September NTA Blog article on the importance of IRS’s IT Modernization can be located here.
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NSA presents this information in the interest of its members for information purposes only and is not intended to provide, nor should it be relied upon, as legal, tax, or accounting advice.