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Remain the best advocate for clients amid scaled-back IRS operations

GettyImages-836660424COVID-19 has altered how businesses, governments and agencies operate around the world. The Internal Revenue Service (IRS) is no different. The IRS recently announced it has scaled back some of its operations.

To protect employees and taxpayers, agents are now working remotely and only holding teleconferences. Scheduled meetings are still likely to take place on their scheduled date virtually, and agents are requesting teleconferences with taxpayers to work their cases.

However, scaled-back operations and staff working remotely doesn’t mean the IRS is unavailable to you.

Contacting the IRS

Proposed regulations hearings are being teleconferenced. Send an email to publichearings@irs.gov to receive the telephone number and access code for specific hearings. And as usual, comments can be submitted by e-mail to the address noted in the proposed rulemaking.

Tax practitioners with e-Services accounts and with client authorization can still access the Transcript Delivery System (TDS) to obtain prior-year transcripts. Check out the AICPA Tax Section’s Using IRS E-Services for tips and tricks for using the tool.

In an exam, ready yourself for multiple teleconferences rather than the usual in-person meeting.

More tips:

  • IRS.gov remains the best source for tax law questions, checks on refund status and tax payments.
  • Although IRS phone lines supported by customer service representatives for both taxpayers and tax professionals are not staffed at this time, automated phone lines, which handle most taxpayer calls, remain available. Some tax compliance lines also remain available. To check on regular tax refund status via automated phone, call 800-829-1954.
  • Reach out to your local Taxpayer Advocate Service for time-sensitive issues, including if a levy situation creates a financial hardship. There may be a message indicating that they will contact you within 24 hours of receiving your voicemail.
  • Send a fax. May sound archaic, but faxes are still a good bet.

Representing your clients

Encourage your clients to use the Where’s My Refund? and Get Transcript services to pull information regarding these items. Clients entitled to a refund and that planned to file paper returns can be encouraged to e-file. Taxpayers also can make tax payments through Direct Pay. The IRS has stated that in “mid-April” taxpayers will be able to check the payment status of their economic impact payments through the Get Your Payment portal. All IRS updates on the economic impact payments and other COVID-19-related issues also will be posted immediately on the Coronavirus Tax Relief and Economic Impact Payments website.

For any notices that you receive offering appeal rights (e.g., rejected offers in compromise, innocent spouse request denial, request to remove a penalty), file the timely protest by certified mail, by mail and by fax to the office that issued the notice or the instructions on the notice. There may not be a person around to accept the certified mail, but by keeping the certified number you can trace the mailing process. Note that the IRS Independent Office of Appeals continues to work its cases and assigned appeals officers can be contacted by phone.

For pending offers in compromise (OIC) applications, the IRS will allow taxpayers until July 15th to provide requested additional information to support a pending OIC, and the IRS will not close any pending OIC request before July 15th without the taxpayer's consent.

Regarding OIC payments, taxpayers may suspend payments on accepted OICs until July 15th. By law, interest will continue to accrue on the unpaid balance.

The IRS will not default an OIC for those taxpayers who are delinquent in filing their tax return for tax year 2018. However, taxpayers should file any delinquent 2018 return (and their 2019 return or extension) on or before July 15th.

For taxpayers under an existing installment agreement, payments due between April 1st and July 15th are suspended. Taxpayers who are currently unable to comply with the terms of an installment agreement, including a direct debit installment agreement, may suspend payments during this period. The IRS will not default any installment agreements during this period. By law, interest will continue to accrue on the unpaid balance.

Request an installment agreement — online or through the mail — with the revenue officer assigned to the case. When requesting installment agreements by mail, remember to include items such as: a list of all periods that are outstanding; the type of tax; the due date of payment requested; and the dollar amount of the payment in the letter. Send the letter by certified mail and regular mail. Ask the taxpayer if he or she would like to send monthly payments to the IRS until he or she (or you) are contacted. Send a cover letter with each payment requesting the installment agreement and include the above stated items.

IRS has suspended new certifications to the Department of State for taxpayers who are "seriously delinquent", which would have prevented taxpayers from receiving or renewing passports. These taxpayers are encouraged to submit a request for an installment agreement or, if applicable, an OIC during this period.

Taxpayers have until July 15th to respond to the IRS to verify that they qualify for the Earned Income Tax Credit or to verify their income. The IRS will not deny these credits for a failure to provide requested information until after July 15th.

Remind your clients to remain current with tax filings and any remaining estimated tax payments and/or employment taxes.

Also, starting on April 17th and until further notice, the IRS will accept eligible refund claims Form 1139 submitted via fax to 844-249-6236 and eligible refund claims Form 1045 submitted via fax to 844-249-6237. Forms that were mailed after March 27th may be re-faxed as well. The IRS has released FAQs on this topic.

IRS operations that have been reduced or suspended

  • Paper correspondence is limited. U.S. Tax Court mail is to be held for delivery until the U.S. Tax Court reopens.
  • Call centers and the Practitioner Priority Service, a special phone line for tax practitioners, is closed.
  • These help-desk lines are also suspended until further notice: e-Services; Filing Information Returns Electronically (FIRE); the Affordable Care Act Information Return (AIR).
  • New Income Verification Express Services (IVES) requests are not being accepted.
  • Central Authorization File (CAF) number authorizations are suspended.
  • Opened new examinations that were not begun in earnest are likely on hold until July 15th.
  • No new examinations are to be opened until after July 15th, provided the statute of limitations does not expire in 2020.
  • Information document requests (IDRs) may be issued and adjustments may still be proposed, however, IDR enforcement procedures have been suspended through July 15th.
  • Fast Track mediation, which is typically 120 days, is likely not available.
  • Most collection activities through the Small Business and Self-Employed Tax Center are suspended through July 15th unless there is a risk of permanent loss to the government due to the expiration of a statute or other exigent circumstance, or the taxpayer has agreed to an action.
  • In general, certain levies and collection notices are suspended until further notice, such as the Federal Payment Levy Program.
  • The 90-day deadline to file a Tax Court petition, after receiving a notice of deficiency, is extended to July 15th.
  • The Philadelphia Accounts Management Campus is currently closed. Thus, the processing of U.S residency certifications is temporarily suspended.

Even during a global pandemic, you have the right to contact the IRS. And even though the IRS has temporarily scaled back many of its normal channels of communication, they still offer essential services.

These tips will help you navigate and remain the best advocate for your clients.

Sarah Shannonhouse, CPA, Manager — Tax, Practice and Ethics, Association of International Certified Professional Accountants Sarah would like to thank Dan Wise, CPA, Head of Tax Risk at CohnReznick and Larry Wolfe, CPA, owner of Larry J. Wolfe Ltd. for their suggestions for this blog post.

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