In her 2014 Annual Report to Congress the National Taxpayer Advocate identified, analyzed, and offered recommendations to assist the IRS and Congress in resolving 23 of the most serious problems (MSPs) encountered by taxpayers. She also made recommendations in conjunction with a study of IRS identity theft procedures.

Congress provided the IRS with the ability to comment on and respond to the National Taxpayer Advocate’s recommendations (in the Annual Reports and elsewhere) by requiring the Commissioner to “establish procedures requiring a formal response to all recommendations submitted to the Commissioner by the National Taxpayer Advocate within three months after submission to the Commissioner.” The IRS has fulfilled its statutory responsibility by preparing written responses to the recommendations in each of the 23 Most Serious Problems and the Volume 2 study in the 2014 report.

The National Taxpayer Advocate also sent the Commissioner of Internal Revenue, at his request, a memorandum identifying select recommendations from the report that she believed could have a significant positive impact on tax administration and could be undertaken or at least explored with minimal resources. The IRS has fully agreed, in principle, with only one of these 12 recommendations, and partially agreed with five recommendations.

The IRS formal comments on our recommendations, together with the National Taxpayer Advocate’s analysis of and responses to the comments, are presented here. In this way, we retain full transparency regarding the IRS’s perspective on our recommendations to address the Most Serious Problems while still complying with the statutory protections.