National Press Foundation

Overview of the
Taxpayer Advocate Service
Your Voice at the IRS

https://TaxpayerAdvocate.irs.gov/
 Erin M. Collins, National Taxpayer Advocate
Taxpayer Advocate Service

Erin Collins is the “voice of the taxpayer” within the IRS and before Congress. She joined
the Taxpayer Advocate Service (TAS) in March 2020 to advocate for taxpayers, protect their
rights, and work toward improving the quality of taxpayer service and tax administration.

Erin has more than 35 years of experience in tax law, spanning 15 years in the IRS Office of
Chief Counsel and 20 years at the accounting firm of KPMG LLP, where she retired in 2019 as
the Tax Managing Director in charge of its tax controversy practice for the Western region.
At KPMG, Erin represented thousands of individuals, partnerships, small companies, and
corporate taxpayers on technical and procedural tax matters. She represented clients in
federal examinations and IRS appeals on domestic and international tax issues. She also has
represented several clients before the U.S. Tax Court.

Erin was the co-author of the Practising Law Institute’s IRS Practice and Procedure Deskbook
and has spoken frequently on IRS practice, procedure, controversy, and litigation matters
before many professional organizations.

Before joining TAS, she represented several clients pro bono to help them resolve issues
with the IRS. She was also a volunteer and board member of a non-profit organization, Step
Up, whose mission was to help girls in under-resourced communities to fulfill their potential
by empowering them to become confident, college-bound, career-focused,
and ready to join the next generation of professional women.
 Who We Are
The Taxpayer Advocate Service (TAS):
• Was established per Internal Revenue Code (IRC) § 7803(c).
• Is an independent organization within the IRS.
• Provides free service to eligible taxpayers, including individuals,
businesses, and nonprofit organizations.
• Imposes no income limits for eligibility.

Statutory Functions of TAS (IRC § 7803(c)(2)):

• Assist taxpayers in resolving problems with IRS.
• Identify areas where taxpayers have problems dealing with IRS.
• Propose changes in IRS’s administrative practices to mitigate problems.
• Identify potential legislative changes to mitigate problems.

As an independent organization within the IRS, we protect taxpayers’

rights under the Taxpayer Bill of Rights, help taxpayers resolve problems
with the IRS, and recommend changes that will prevent the problems.
 What We Do
• Protect taxpayers’ rights by striving to ensure taxpayers are
treated fairly and understand their rights under TBOR.
• Help taxpayers where efforts failed to resolve a problem, or a
system failed to operate as intended within the IRS (case and
systemic advocacy).
• Provide reports to Congress – twice annually.
• Administer, support, and partner with Low Income Taxpayer
Clinics (LITCs) and the Taxpayer Advocacy Panel (TAP).
 Congress codified the
Taxpayer Bill of Rights
(TBOR).

 All IRS employees are

responsible for ensuring
taxpayer rights are
considered and
protected.

 Publication 1, Your Rights

as a Taxpayer, includes
the taxpayer rights from
TBOR.
 TAS Organization and Offices
• The National Taxpayer Advocate (NTA) is appointed by the
Secretary of Treasury and reports directly to the Commissioner
of Internal Revenue.
• TAS has 80 local offices in addition to its headquarters location
(1111 Constitution Avenue, Washington, DC).
◦ At least one Local Taxpayer Advocate (LTA) office is in every state,
the District of Columbia, and Puerto Rico.
• TAS has over 1600 employees.
• TAS has three key functions:
◦ Case Advocacy
◦ Systemic Advocacy
◦ Research
 Division Counsel/Associate Chief Counsel
(National Taxpayer Advocate Program)
National Taxpayer Advocate
Executive Director
Systemic Advocacy
(EDSA)
Senior Advisor to NTA

Senior Advisor to NTA – Research

Deputy EDSA, Deputy EDSA,
Equity, Diversity & Proactive Technical
Financial Operations Inclusion Advocacy Advocacy
Attorney Advisors Director Director
Deputy National Taxpayer Advocate
HR Director Labor Relations
Collectio
Research & Analysis Director ARC Program n
Managers Technical

Executive Director Assistant to Advocac

Business Executive Director
Low Income Taxpayer Clinic Director Case Advocacy EDCA y
Strateg y Assessment Executive Director
Modernizatio & Employee (EDCA) Case Advocacy ITS Director
n Director Develo pment (EDCA)
Advocacy Exam
Intake & Technical Implementatio Technical
Support DC LTA n & Evaluation
Low Income Taxpayer Clinic
Director Advocac
Deputy Director
y
SAED, Deputy Assistant to Assistant to Director
TAS Technical EDCA EDCA
Executive Director, Communications, TAS Business Director Processin
Systems
Support Office East West Deputy EDCA
Stakeholder Liaison & Online Services Support Office Deputy EDCA
ITS Technical g
(CSO) ITS Intake
Support Technical
Advocacy Advocacy
Quality Review Deputy EDCA Deputy EDCA Efforts Director
Program Director Area 1 Area 5 Director
Deputy Director, CSO Internal
Technica Centralized
l Advisor Case
Deputy EDCA Deputy EDCA
ES&D Director Program Intake
Area 2 Area 6
Director Director
Taxpayer
Marketing & Multimedia &
Advoca cy Pa
Communicatio ns Techno logy
nel Director
Leadership Business Deputy EDCA Deputy EDCA Technical
Developmen Assessmen Area 3 Area 7 Analysis &
t Office t Director Guidance CCI CCI CCI
Director Departmen Departmen Departmen
t Manager t Manager t Manager
Deputy EDCA Deputy EDCA East Central West
Area 4 Area 8

Area 1 Area 2 Area 3 Area 4 Area 5 Area 6 Area 7 Area 8

12 Offices 9 Offices 9 Offices 9 Offices 8 Offices 10 Offices 10 Offices 11 Offices
Albany, NY Baltimore, MD Atlanta City Ctr, Cincinnati, OH Austin, TX Chicago, IL Albuquerque, Fresno, CA
Andover, MA Charlotte, NC GA Atlanta, GA Cleveland, OH Dallas, TX Des Moines, IA NM Las Vegas, Laguna Niguel, CA
Augusta, ME Greensboro, NC Birmingham, AL Northern KY Houston, TX Kansas City, NV Phoenix, AZ Los Angeles, CA
Boston, MA Newark, DE Columbia, SC Detroit, MI Jackson, MS MO Milwaukee, Cheyenne, WY Oakland, CA
Brookhaven, NY Philadelphia, PA Ft Lauderdale, Indianapolis, IN Little Rock, AR WI Springfield, Denver, CO Sacramento, CA
Brooklyn, NY Pittsburgh, PA FL Jacksonville, Louisville, KY New Orleans, LA IL St. Louis, MO Boise, ID San Diego, CA
Buffalo, NY Richmond, VA FL Puerto Rico Memphis, TN Oklahoma City, St. Paul, MN Helena, San Jose, CA
Burlington, VT Springfield, NJ St Petersburg, Nashville, TN OK Wichita, KS MT Ogden, Anchorage, AK
Hartford, CT Trenton, NJ FL Tallahassee, Parkersburg, El Paso, TX Fargo, ND UT Honolulu, HI
Manhattan, NY FL WV Sioux Falls, Omaha, NE Portland, OR
Providence, RI SD Salt Lake Seattle, WA
Portsmouth, NH City, UT
 TAS Case Advocacy
• TAS provides independent, impartial, and confidential advocacy on
behalf of taxpayers.
• Case Advocacy helps TAS fulfill its mission to assist taxpayers with
their specific issues and concerns involving IRS systems and
procedures.
• Taxpayers may be eligible for TAS help if they:
◦ Have a tax problem they haven’t been able to resolve on their own;
◦ Are having financial difficulty due to their IRS problem; or
◦ They believe an IRS procedure just isn’t working as it should.
• In FY 20, TAS opened 206,772 cases and assisted over 30,000
taxpayers on the Centralized Case Intake phone lines.
• Through the 2nd quarter of FY 21, TAS opened 121,764 cases.
◦ TAS continues to see a significant increase in receipts from IRS
operations that rely on employees being physically present to complete
the work, such as Unpostables and Rejects, Health Insurance Premium
Tax Credit for Individual, and Processing Original and Amended Returns.
 Case Advocacy – Case Acceptance Criteria
Economic
 Suffering economic harm
 Facing adverse action
 Will incur significant cost
 Will suffer irreparable injury
Systemic
 Significant delay of more than 30 days
 No response/resolution by date promised
 Systemic or procedural failure
Best Interest of the Taxpayer: The manner in which the tax laws are being
administered raises considerations of equity, or have impaired, or will impair
the taxpayer's rights.
Public Policy: The NTA determines compelling public policy considerations
warrant special assistance for an individual or group of taxpayers.
 Case Advocacy – Sources of Case Work
Sources of Casework (FY 21 through March 2021)
 Case Advocacy – Casework and Case Issues
• Through March FY 21, TAS receipts increased by 25% compared to
the same period in FY 20.
• In the first half of FY 21, compared to the same period in FY 20:
◦ TAS congressional contacts increased by 310%.
◦ TAS phone call contacts increased by 15%.
◦ NTA Toll-Free contacts increased by 35% and Centralized Case Intake
phone contacts increased by 36%.

• Examples of case issues worked by TAS:

o Pre-Refund Wage Verification
Hold
o Open EITC Audit
o Processing Amended Return
o Identity Theft
o Injured Spouse Claim
o Civil Penalties
o Audit Reconsideration
o Math Error
o Innocent Spouse Appeal
o Tax Treaties
 Case Advocacy – How We Work with IRS
• Service Level Agreements (SLAs)
◦ Each IRS Operating Division (OD) has a TAS liaison.
• Operations Assistance Requests (OARs)
◦ Used by TAS to request assistance from an IRS OD/function to
complete an action on a TAS case when TAS does not have the
authority to take the required action(s).
• Taxpayer Assistance Orders (TAOs)
◦ IRC § 7811 provides the authority for TAS to issue a TAO.
◦ A TAO may be issued when a taxpayer is suffering or is about to
suffer a significant hardship as a result of the manner in which the
internal revenue laws are being administered by the IRS, including
actions or inactions.
 TAS Systemic Advocacy

• Systemic Advocacy studies and seeks to resolve problems that

affect groups of taxpayers, including problems that affect
individuals, businesses, or both.
• Systemic issues:
◦ Affect multiple taxpayers; are not individual problems or cases.
◦ Require analysis, administrative solutions, or legislative changes.
◦ Involve protecting taxpayer’s rights, reducing or preventing taxpayer
burden, ensuring equitable treatment of taxpayers, or providing
essential services to taxpayers.
• Sources of Systemic Advocacy work:
◦ TAS Case Advocates
◦ Other IRS employees
◦ The Public
◦ Other external stakeholders through the Systemic Advocacy
Management System (SAMs)
Systemic Advocacy – Systemic Work and Issues
• Categories of Systemic Advocacy work:
◦ Advocacy Projects
◦ Information Gathering Projects
◦ Annual Reports to Congress
◦ Collaborative efforts with IRS (task forces,
Executive Steering Committees, etc.)

• Examples of systemic issues worked by TAS:

o Economic Impact Payments o Collection
(EIP) o Installment Agreement
o Identity Theft o Processing Error
o Forms or Publications o Examination
o Correspondence Review
 Systemic Issues - How You Can Help!
• Know of a tax problem that affects more than one taxpayer?
• Does the issue involve:
◦ IRS systems, policies, and procedures; or
◦ Protecting taxpayer rights, reducing burden, ensuring fair
treatment, or providing essential taxpayer services?

We look for patterns in the problems our case advocates handle,

but also need help from our internal and external partners
in identifying large-scale or systemic problems that
affect many taxpayers.

If you know of one of these broad issues, tell us about it at

www.irs.gov/sams
 Research
TAS has developed a strong research function that sponsors or
participates in theoretical, cognitive, and applied research initiatives to
improve tax administration.

This research is designed to improve the effectiveness of both taxpayer

service initiatives and enforcement initiatives and to aid the IRS in
increasing voluntary compliance.
 NTA Blog Posts
• Lifecycle of a Tax Return
• Claims for Refunds: 2019 and 2020 Tax Year Trap for the Unwary
• 2021 Filing Season Bumps in the Road: Part I
• 2021 Filing Season Bumps in the Road: Part II
• Paycheck Protection Plan Loan Forgiveness and Deductibility of Associated Expenses
• Erroneously claiming certain refundable tax credits could lead to being banned from
claiming the credits
• Most Taxpayers Needing a New ITIN Are Prohibited From Filing Electronically,
Causing Unnecessary Refund Delays
• Did you File a Superseding Return? If so, Read on.
• NTA Blog: Not all Superheroes Wear Capes: Join the Low Income Taxpayer Clinic
Community and Be a Hero to Taxpayers Most in Need
• Stretched to Its Breaking Point, the IRS Needs Multiyear, Sustained Funding to
Efficiently Administer the Tax Laws and Provide Quality Service for Taxpayers
• Update on Offset of Recovery Rebate Credits: The IRS Has Agreed to Exercise Its
Discretion to Stop Offsets of Federal Tax Debts
• Identity Protection PIN Can Protect You From Tax-Related Identity Theft
• Wait, When Did This Virtual Currency Question Appear on My 1040 Tax Form?

https://www.taxpayeradvocate.irs.gov/news-category/nta-blog/
 NTA Blog Posts (cont.)
• The IRS May Consult a Ten-Year-Old Tax Return to Decide Whether to Exclude Your
Account From Its Private Debt Collection Program
• Proposed Disaster Regulations – March 15 is the last day for public comment
• The IRS Increases Cost of a Private Letter Ruling (PLR) and Now a Fee for Estate Tax
Closing Letters.  The IRS Is Seeking Comments by March 1.
• If You Didn’t Get Your EIP, Your Joint Return May Be the Reason Why
• March Is IRS’s National Settlement Month for Unrepresented Taxpayers With a Tax
Court Docketed Case
• March Is IRS’s National Settlement Month for Unrepresented Taxpayers With a Tax
Court Docketed Case
• Many Taxpayers May Not Receive the Full Amount of Economic Impact Payments to
Which They Are Entitled, but the IRS Has the Discretion to Correct the Resulting
Injustice
• IRS Notices Delayed (Again): Look for Insert With Revised Deadlines for Certain
Notices

https://www.taxpayeradvocate.irs.gov/news-category/nta-blog/
or Subscribe!
 TAS Reports
IRC § 7803(c)(2)(B) requires the NTA to submit two annual reports to the
Committee on Ways and Means of the House of Representatives and the
Committee on Finance of the Senate: 

Objectives Report: By June 30,
the NTA shall report on the
objectives of TAS for the
upcoming fiscal year.
Annual Report: By Dec. 31, the NTA shall report
on TAS activities during the prior fiscal year, and
include, in addition to other topics, a summary
of the ten most serious problems encountered
by taxpayers and the ten most litigated issues.

19
2020 Annual Report to Congress (ARC) Topics:
◦ Most Serious Problems Encountered by Taxpayers
◦ Most Litigated Issues
◦ Supplemental Review of the 2020 Filing Season
◦ TAS Advocacy Successes
◦ TAS Case Advocacy
◦ Legislative Recommendations (included in the Purple Book)
◦ Research Study

https://www.taxpayeradvocate.irs.gov/reports/2020-annual-report-to-cong
ress/
 2020 Most Serious Problems
1. IRS Recruitment, Hiring, and Employee Retention: Quality Taxpayer
Service and Protection of Taxpayer Rights Are Directly Linked to the IRS’s
Need to Improve Its Recruitment, Hiring, and Retention Strategies
2. Telephone and In-person Service: Taxpayers Face Significant Difficulty
Reaching IRS Representatives Due to Outdated Information Technology
and Insufficient Staffing
3. Online Records Access: Limited Electronic Access to Taxpayer Records
Through an Online Account Makes Problem Resolution Difficult for
Taxpayers and Results in Inefficient Tax Administration
4. Digital Communications: Limited Digital Communications with the IRS
Make Problem Resolution Unnecessarily Difficult for Taxpayers
5. E-Filing and Digitalization Technology: Failure to Expand Digitalization
Technology Leaves Millions of Taxpayers Without Access to Electronic Filing
and Wastes IRS Resources
 2020 Most Serious Problems (cont.)
6. Information Technology Modernization: Antiquated Technology
Jeopardizes Current and Future Tax Administration, Impairing Both
Taxpayer Service and Enforcement Efforts
7. Correspondence Exams: Taxpayers Encounter Unnecessary Delays and
Difficulties Reaching an Accountable and Knowledgeable Contact for
Correspondence Audits
8. International: The IRS’s Assessment of International Penalties Under
IRC §§ 6038 and 6038A is Not Supported by Statute, and Systemic
Assessments Burden Both Taxpayers and the IRS
9. Amended Returns: The IRS Processes Most Amended Returns Timely but
Some Linger for Months, Generating Over a Million Calls that the IRS
Cannot Answer and Thousands of TAS Cases Each Year
10. Refund Delays: Taxpayers Whose Legitimate Returns are Flagged by IRS
Fraud Filters Experience Excessive Delays and Frustration in Receiving
their Refunds
 Legislative Recommendations
2021 Purple Book contains 66 legislative recommendations, e.g.:
• Provide the IRS with sufficient funding to meet taxpayer needs and
improve tax compliance.
• Authorize the IRS to establish minimum standards for tax return preparers.
 
• Expand the U.S. Tax Court’s jurisdiction to hear refund cases.  
• Restructure the Earned Income Tax Credit (EITC) to make it simpler for
taxpayers and reduce improper payments.  
• Increase the annual award cap for Low Income Taxpayer Clinics (LITCs).
• Clarify that supervisory approval is required before the IRS imposes
certain penalties.  
• Require taxpayer consent before allowing IRS Counsel or Compliance
personnel to participate in IRS Independent Office of Appeals conferences.
• Clarify that taxpayers may raise innocent spouse relief as a defense in
collection proceedings and bankruptcy cases.
• Clarify that the NTA may hire independent legal counsel.  
 2020 Filing Season Review
• 2020 filing season severely disrupted by COVID.
• Individual income tax returns filing/payment date extended to July 15.
• Taxpayers negatively impacted due to campus closures, Taxpayer
Assistance Center closures, and stay at home orders for employees.
• Substantial reduction in Volunteer Income Tax Assistance, Tax Counseling
for the Elderly, and LITC services.
• IRS not able to track or respond to correspondence.
• W&I Business OD hiring was 57% of FY 20 hiring goals.
• Challenges with timing of first EIP and inability to correct those payments
with changed circumstances.
• Estimated 160M 1040s; 152M filed by July 15; 100M requested refunds.
• IRS.gov web traffic more than tripled; Where’s My Refund increased 48%.
• Over 3.2M returns flagged for potential fraud and approx. 88% released
through July 15.
• By Dec. 20, over 6.9M paper 1040 and 2.3M business returns
unprocessed.
 Highlights of TAS 2020 Accomplishments

• Updated 133 IRS Internal Revenue Manuals (IRMs), incorporated TBOR into
44 IRMs, and helped revise 23 taxpayer notices, 11 tax forms, and five
publications.
• Persuaded the IRS to include a due date to request a hearing in Collection
Due Process notices caught up in COVID-related backlogs.
• Secured emergency financial relief for thousands missed during the initial
EIP distributions once the IRS responded to TAS concerns with systemic fixes
and manual adjustments that provided taxpayers corrected EIP amounts.
• Used existing and new resolution authorities, and worked collaboratively
with the IRS, to resolve an IRS backlog of over 6,000 unresolved TAS OARs,
which TAS uses to secure relief for taxpayers experiencing financial and
economic harm.
• Helped military taxpayers obtain missing W-2 forms to receive timely
refunds and EIPs.
 Highlights of TAS 2020 Accomplishments (cont.)

• Elevated erroneously disallowed Form 7004 extension requests to the IRS,

resulting in penalty abatement on over 200 affected taxpayer accounts.
• Advocated successfully for new or improved tools to:
◦ Allow the IRS to more quickly validate information for refundable credits.
◦ Allow Spanish speaking taxpayers to better understand documentation
needed to substantiate Earned Income Tax Credit (EITC) claims.
• Advocated for new IRS procedures explaining to taxpayers that they should
compare their return information against every income statement, and if
they don’t match, they should file an amended return.
• Worked with the IRS to expedite the issuance of math error notices with
inserts providing revised dates for notices that were not printed or mailed
timely due to COVID, thus ensuring taxpayers were informed of the
extension and could avoid accruing penalties and interest.
 Low Income Taxpayer Clinic Program
TAS’s Low Income Taxpayer Clinic (LITC)
grant program provides matching grants of
up to $100,000 per year to organizations
that operate an LITC.
Publication 4134, Low Income Taxpayer
Clinic List, provides contact info. for the 129
LITCs funded in 2021.
For more information visit:
www.taxpayeradvocate.irs.gov/litc
*The application period for 2022 LITC grants opened
May 3 and closes June 18, 2021. See irs.gov.
LITCs ensure the fairness and
integrity of the tax system for
taxpayers who are low-income
or speak English as a second
language (ESL) by:
 Providing pro bono
representation on their
behalf in tax disputes with
the IRS;
 Educating them about their
rights and responsibilities
as taxpayers; and
 Identifying and advocating
for issues that impact these
taxpayers.
 Low Income Taxpayer Clinic Program (cont.)

The 2020 Low Income Taxpayer Clinic (LITC) Program Report describes how LITCs provide
representation, education, and advocacy for taxpayers who are low-income or speak
English as a second language. It includes examples of LITCs’ accomplishments on behalf of
taxpayers during the 2019 grant year:

• Represented 20,259 taxpayers dealing with an IRS tax controversy.

• Reduced taxpayers' liabilities by more than $50 million. 
• Helped taxpayers secure more than $6.8 million in tax refunds. 
• Brought more than 4,156 taxpayers back into payment compliance.  
• Conducted more than 1,800 educational activities attended by over 41,840 individuals.
• Leveraged the support of more than 1,500 volunteers who offered over 52,500
hours of their time.
◦ More than two-thirds of the volunteers were attorneys, certified public accountants, or
enrolled agents.
 Taxpayer Advocacy Panel
The Taxpayer Advocacy Panel (TAP) is a
federal advisory committee established
under the authority of Treasury.
TAP is comprised of about 75 members
who volunteer to serve a three-year
term, and represent all 50 states, the
District of Columbia, Puerto Rico, and
U.S. citizens living or working abroad.
For more information, visit:
www.improveirs.org/
TAP’s mission is to listen to
taxpayers, identify taxpayers’
issues, and make suggestions for
improving IRS service and customer
satisfaction. TAP performs
grassroots outreach activities to
identify issues raised by taxpayers.
TAP Referrals to IRS:
• 2018: 22 referrals w/ 152
recommendations
• 2019: 51 referrals w/ 124
recommendations
• 2020: 58 referrals w/ 237
recommendations
 How to Contact TAS
TAS has at least one Local Taxpayer Advocate (LTA) office in
every state, the District of Columbia, and Puerto Rico.

• LTA phone and fax numbers are in your local directory and at:
taxpayeradvocate.irs.gov/contact-us
• Fax or phone the LTA offices listed in Publication 1546, Taxpayer Advocate
Service We are Here to Help You
• Call the NTA’s Toll-Free Intake Line: 1-877-777-4778
• Download Form 911, Request for Taxpayer Advocate Service Assistance (And
Application for Taxpayer Assistance Order), from IRS.gov
 Want to Know More?
Visit TAS’s website at: https://taxpayeradvocate.irs.gov
(English and Spanish) Our Tax Toolkit can help taxpayers
understand their rights and get basic tax information,
details about individual and business tax credits, and more.

Check out our Tax Professional page, too:

https://taxpayeradvocate.irs.gov/tax-professionals

NTA Blog:
https://TaxpayerAdvocate.irs.gov/about/nta-blog

Follow TAS on Social Media:

• Facebook: http://www.facebook.com/YourVoiceatIRS
• Twitter: http://www.twitter.com/YourVoiceatIRS
• YouTube: http://www.youtube.com/TASNTA
• LinkedIn:
https://www.linkedin.com/company/taxpayer- advocate-
service