The Treasury Inspector General for Tax Administration (TIGTA) has published the details of its audit of the Taxpayer Advocate Service's (TAS) Office of Systemic Advocacy. (Audit Report No. 2025-300-006)
The audit was initiated to evaluate the efficiency and effectiveness of the Office of Systemic Advocacy and determine the extent to which the office fulfills its mission, TIGTA said.
As described in the audit, TAS is responsible for the identification and resolution of systemic, procedural, and legislative issues that may affect taxpayers. TAS considers a problem to be systemic if the impact:
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Affects multiple taxpayers.
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Involves IRS systems, policies, or procedures.
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Affects taxpayer rights, increases taxpayer burden, causes disparate treatment of taxpayers, or involves essential taxpayer services.
"To resolve systemic problems that impact taxpayers, the Office of Systemic Advocacy sometimes works with the IRS using cross functional teams," the audit explained, adding that "these collaborative teams may include Office of Systemic Advocacy analysts and IRS employees from various business operating divisions."
A review of 26 collaborative teams that closed during a 21-month period found that only six teams (or 23%) had both a documented objective or mission and a measurable outcome.
"The Remaining 20 Teams Lacked A Documented
Objective Or Mission, Did Not Have A
Measurable Outcome, Or Both," TIGTA Said.
The Office of Systemic Advocacy does not conduct quality reviews of the collaborative teams, it added.
Further, "TAS has not developed additional performance measures to capture the overall effectiveness of advocacy projects and their impact on tax administration from a previous TIGTA recommendation they agreed to in Fiscal Year 2011," the audit said.
In addition, "issues submitted by taxpayers and other stakeholders into the Systemic Advocacy Management System (SAMS) and resulting information gathering projects were not always reviewed or worked timely," TIGTA said. The audit offered examples in support of this conclusion.
Of the 9,400 systemic and non-systemic issues closed from SAMS in FY 2022, 809 (9 percent) issues were not reviewed timely and took more than 40 days to close. Of the 809 untimely issues, 147 issues took over 90 days.
The IRM states that in general, the recommended treatment for the issue should be developed within 40 business days. Depending on the complexity of the issue, some issues are resolved within a few days, but others may take longer. For example, an issue may take longer if it requires a subject matter expert to help evaluate the issue.
We selected a judgmental sample of 51 issues (31 systemic issues and 20 non-systemic issues) from the 9,400 issues closed in SAMS in FY 2022 and found that:
- 40 of the 51 sampled issues were not reviewed timely.
- 20 • 20 systemic issues took from 61 to 217 days to resolve.
- We did not find a reason in the case file for why these issues were untimely.
- The remaining 11 issues were either reviewed timely or had the reasons for the delays documented in the case file.
- 20 non-systemic issues took from 92 to 186 days to resolve. We did not find a reason in the case file why these issues were untimely.
- TAS management agreed that the 40 issues were untimely and responded that some of the causes for not meeting the 40-day requirement included:
- 20 issues were delayed due to staffing. TAS management stated that in FY 2022, TAS experienced a significant increase in SAMS issue inventory, along with analysts being detailed to the SIRE group, which required the permanent staff to train them (the SIRE group only had three permanent analysts and two detailed analysts).
- Additionally, staffing issues affected their technical teams and IRS function employees who provided input and research on the issues.
- 20 issues were delayed due to improper management of an employee’s inventory. TAS management said that they developed inventory management tools, including inventory
"Finally, the Office of Systemic Advocacy does not analyze the SAMS submissions to determine if trends in systemic issues exist or monitor or track systemic issues that are closed prior to resolution," the audit said.
TIGTA made 11 recommendations and, according to the audit, TAS agreed with all of the recommendation and "plans to take corrective actions."
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