Tax Administration
Opportunities Exist for IRS to Enhance Taxpayer Service and Enforcement for the 2010 Filing Season
Gao ID: GAO-09-1026 September 23, 2009
Preparing for the tax filing season is a significant undertaking for Internal Revenue Service (IRS). The filing season is when most individuals file their tax returns, receive refunds, and contact IRS if they have questions. As returns are received, IRS begins a series of automated compliance checks to correct errors on tax returns and ensure that refunds are justified. For example, IRS rejects electronically filed returns with basic errors requiring taxpayers to correct and resubmit them. It uses what is called "math error authority" to automatically correct obvious noncompliance such as violations of limits on deductions or credits, which allows IRS to avoid costly audits. IRS must begin preparing for each filing season months in advance and preparations include the following. (1) Revising tax forms and publications to implement tax law changes. Recent major law changes that affected the 2009 filing season include the (a) Economic Stimulus Act of 2008, which contained the recovery rebate credit allowing taxpayers who did not receive the full economic stimulus payment last year to claim some or all of the unpaid credit on their 2008 returns; (b) Housing and Economic Recovery Act of 2008 (Housing Act), which included a first-time homebuyer credit of up to $7,500; and (c) American Recovery and Reinvestment Act of 2009 (Recovery Act), which increased the maximum credit to $8,000 and eliminated the payback provision of the first-time homebuyer credit for homes purchased before December 1, 2009. (2) Reprogramming and testing computer systems to incorporate tax law changes. (3) Hiring and training telephone assistors, many of whom are temporary hires employed for the filing season. (3) Coordinating with the paid preparer and tax software industries, which serve as important intermediaries between IRS and taxpayers and prepare close to 90 percent of all returns and all electronically filed returns. IRS also coordinates with a network of volunteer tax return preparers who help elderly individuals and others prepare their tax returns at over 12,000 volunteer sites. Because of the magnitude and importance of the filing season, you requested that we review IRS's 2009 filing season performance.
IRS may be missing opportunities to improve taxpayer service and enhance compliance for the 2010 filing season for the following reasons. (1) IRS lacks a strategy for preventing and resolving errors that cause electronically filed returns to be rejected. Without a strategy that documents, for example, its objectives, the role of external stakeholders, and schedules for specific actions, IRS may be missing an opportunity to make electronic filing less cumbersome for taxpayers. (2) IRS does not fully leverage the expertise of external stakeholders in its efforts to reduce rejected electronic returns, according to industry representatives, the Treasury Inspector General for Tax Administration, and an IRS advisory group. IRS has established an internal working group to reduce rejects and simplify error codes, but that group does not include industry representatives. Without soliciting the expertise of these stakeholders, IRS may be missing an opportunity to better understand why rejects occur and what can be done to prevent them. (3) IRS acknowledges that its codes for errors on electronically filed tax returns are not very useful for helping taxpayers resolve the errors and has established the reject working group, but IRS does not have an action plan for implementing improvements. Without such an action plan, the working group risks being less effective in developing more useful reject codes. (4) The electronic acknowledgments that IRS sends to paid preparers, software providers, and taxpayers about rejected electronic returns are confusing and unclear. Unclear notices frustrate taxpayers and increase IRS's costs because such notices generate phone calls from taxpayers (see app. II for more information on the common error reject codes in 2009 and IRS's electronic acknowledgments). (5) According to IRS, its assistors answered 3 million calls from taxpayers needing authentication to file electronically, nearly 10 percent of all assistor calls, at a cost of $36 million through June 2009. Instead of relying on assistors to provide taxpayers with this information, IRS recently began developing an automated application for authenticating electronic filers, which could increase efficiency by diverting some calls currently answered by IRS telephone assistors. The new application is scheduled to launch on January 18, 2010. As of August 26, 2009, IRS officials reported that they were on schedule. If IRS were to experience any slippage in the launch date, it would be missing an opportunity to reduce call volume at the beginning of the filing season. (6) IRS lacks an automated means for helping taxpayers locate its 12,000 volunteer tax preparation sites or their hours of operation. In the 2009 filing season, taxpayers contacting IRS for this information had to call IRS and speak to an IRS assistor. Assistors have a list of volunteer site locations and hours that is updated twice a week. However, that information is not on IRS's Web site. Low-cost options, such as posting IRS's existing list of volunteer sites on its Web site, could eliminate some calls currently being answered by IRS assistors. (7) IRS lacks math error authority, which must be provided by statute for specific purposes, to verify compliance with two aspects of the first-time homebuyer tax credit. First, IRS would have to use labor-intensive audits to ensure compliance with the repayment provision of the 2008 credit--according to IRS, 1.2 million taxpayers claimed the 2008 credit for a total of $8.6 billion that must be repaid. Similarly, IRS has to use audits to ensure taxpayers do not claim the credit for both 2008 and 2009. Because math error checks are automated and could substitute for burdensome audits, IRS could check all returns at relatively low cost with such authority.
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GAO-09-1026, Tax Administration: Opportunities Exist for IRS to Enhance Taxpayer Service and Enforcement for the 2010 Filing Season
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Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
September 2009:
Tax Administration:
Opportunities Exist for IRS to Enhance Taxpayer Service and Enforcement
for the 2010 Filing Season:
GAO-09-1026:
Contents:
Letter:
Results:
Conclusions:
Matters for Congressional Consideration:
Recommendations for Executive Action:
Agency Comments:
Appendix I: Updated Slides from the September 1, 2009, Briefing:
Appendix II: Most Common Error Reject Codes in the 2009 Filing Season
and IRS Descriptions:
Appendix III: GAO Contact and Staff Acknowledgments:
Table:
Table 1: Most Common Error Reject Codes and IRS Descriptions for the
2009 Filing Season:
Abbreviations:
AGI: adjusted gross income:
DOB: date of birth:
EIC: Earned Income Tax Credit:
EIN: employer identification number:
ERC: error reject code:
ETAAC: Electronic Tax Administration Advisory Committee:
IRS: Internal Revenue Service:
PIN: personal identification number:
SEQ: sequence number:
SSA: Social Security Administration:
SSN: Social Security number:
TIGTA: Treasury Inspector General for Tax Administration:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
September 23, 2009:
The Honorable Max Baucus:
Chairman:
The Honorable Charles E. Grassley:
Ranking Member:
Committee on Finance:
United States Senate:
The Honorable John R. Lewis:
Chairman:
The Honorable Charles W. Boustany Jr.
Ranking Member:
Subcommittee on Oversight:
Committee on Ways and Means:
House of Representatives:
Preparing for the tax filing season is a significant undertaking for
Internal Revenue Service (IRS). The filing season is when most
individuals file their tax returns, receive refunds, and contact IRS if
they have questions.[Footnote 1] As returns are received, IRS begins a
series of automated compliance checks to correct errors on tax returns
and ensure that refunds are justified. For example, IRS rejects
electronically filed returns with basic errors requiring taxpayers to
correct and resubmit them. It uses what is called "math error
authority" to automatically correct obvious noncompliance such as
violations of limits on deductions or credits, which allows IRS to
avoid costly audits.[Footnote 2] As we reported earlier to you, from
January 1 through May 15, 2009, IRS had processed over 120 million
returns, issued over 100 million refunds, received 66 million telephone
calls, and answered 20 million calls using nearly 12,000 assistors.
[Footnote 3]
IRS must begin preparing for each filing season months in advance and
preparations include the following.
* Revising tax forms and publications to implement tax law changes.
Recent major law changes that affected the 2009 filing season include
the:
- Economic Stimulus Act of 2008, which contained the recovery rebate
credit allowing taxpayers who did not receive the full economic
stimulus payment last year to claim some or all of the unpaid credit on
their 2008 returns;[Footnote 4]
- Housing and Economic Recovery Act of 2008 (Housing Act), which
included a first-time homebuyer credit of up to $7,500;[Footnote 5]
and:
- American Recovery and Reinvestment Act of 2009 (Recovery Act), which
increased the maximum credit to $8,000 and eliminated the payback
provision of the first-time homebuyer credit for homes purchased before
December 1, 2009.[Footnote 6]
* Reprogramming and testing computer systems to incorporate tax law
changes.
* Hiring and training telephone assistors, many of whom are temporary
hires employed for the filing season.
* Coordinating with the paid preparer and tax software industries,
which serve as important intermediaries between IRS and taxpayers and
prepare close to 90 percent of all returns and all electronically filed
returns.[Footnote 7] IRS also coordinates with a network of volunteer
tax return preparers who help elderly individuals and others prepare
their tax returns at over 12,000 volunteer sites.
Because of the magnitude and importance of the filing season, you
requested that we review IRS's 2009 filing season performance. As part
of that review, we looked for opportunities to improve service and
enhance enforcement in time for the 2010 filing season, which this
report addresses. On September 1, 2009, we briefed Subcommittee on
Oversight, House Committee on Ways and Means, and Senate Committee on
Finance staff on opportunities for IRS to enhance taxpayer service and
enforcement for the 2010 filing season. This report transmits the
updated briefing materials, which are reprinted in appendix I. Our
report on IRS's 2009 filing season performance will be issued in
November.
To identify opportunities to make improvements for 2010, we obtained
and analyzed IRS's performance and production data and compared them to
annual goals and prior years' performance; viewed IRS operations;
reviewed relevant external documentation including our reports and
reports of the Treasury Inspector General for Tax Administration; and
interviewed IRS officials and representatives of paid preparers and tax
software developers. We conducted our work primarily at IRS
Headquarters in Washington, D.C., and division and field offices,
including those in Atlanta, Georgia. We previously assessed IRS's
filing season performance data for reliability. For example, we
considered filing season performance measures and data that cover the
quality, accessibility, and timeliness of IRS's services to be
objective and reliable based on that work. Since the data sources and
procedures for producing this year's filing season data have not
significantly changed from prior years, we determined that the data
were sufficiently reliable for the purposes of this report. To the
extent possible, we corroborated information from interviews with
documentation and data, and where this was not possible, we report the
information as attributed to IRS officials. We conducted this
performance audit from January 2009 through September 2009 in
accordance with generally accepted government auditing standards. Those
standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our objectives.
Results:
IRS may be missing opportunities to improve taxpayer service and
enhance compliance for the 2010 filing season for the following
reasons.
* IRS lacks a strategy for preventing and resolving errors that cause
electronically filed returns to be rejected. Without a strategy that
documents, for example, its objectives, the role of external
stakeholders, and schedules for specific actions, IRS may be missing an
opportunity to make electronic filing less cumbersome for taxpayers.
* IRS does not fully leverage the expertise of external stakeholders in
its efforts to reduce rejected electronic returns, according to
industry representatives, the Treasury Inspector General for Tax
Administration, and an IRS advisory group. IRS has established an
internal working group to reduce rejects and simplify error codes, but
that group does not include industry representatives. Without
soliciting the expertise of these stakeholders, IRS may be missing an
opportunity to better understand why rejects occur and what can be done
to prevent them.
* IRS acknowledges that its codes for errors on electronically filed
tax returns are not very useful for helping taxpayers resolve the
errors and has established the reject working group, but IRS does not
have an action plan for implementing improvements. Without such an
action plan, the working group risks being less effective in developing
more useful reject codes.
* The electronic acknowledgments that IRS sends to paid preparers,
software providers, and taxpayers about rejected electronic returns are
confusing and unclear. Unclear notices frustrate taxpayers and increase
IRS's costs because such notices generate phone calls from taxpayers
(see appendix II for more information on the common error reject codes
in 2009 and IRS's electronic acknowledgments).
* According to IRS, its assistors answered 3 million calls from
taxpayers needing authentication to file electronically, nearly 10
percent of all assistor calls, at a cost of $36 million through June
2009. Instead of relying on assistors to provide taxpayers with this
information, IRS recently began developing an automated application for
authenticating electronic filers, which could increase efficiency by
diverting some calls currently answered by IRS telephone assistors. The
new application is scheduled to launch on January 18, 2010. As of
August 26, 2009, IRS officials reported that they were on schedule. If
IRS were to experience any slippage in the launch date, it would be
missing an opportunity to reduce call volume at the beginning of the
filing season.
* IRS lacks an automated means for helping taxpayers locate its 12,000
volunteer tax preparation sites or their hours of operation. In the
2009 filing season, taxpayers contacting IRS for this information had
to call IRS and speak to an IRS assistor. Assistors have a list of
volunteer site locations and hours that is updated twice a week.
However, that information is not on IRS's Web site. Low-cost options,
such as posting IRS's existing list of volunteer sites on its Web site,
could eliminate some calls currently being answered by IRS assistors.
* IRS lacks math error authority, which must be provided by statute for
specific purposes, to verify compliance with two aspects of the first-
time homebuyer tax credit. First, IRS would have to use labor-intensive
audits to ensure compliance with the repayment provision of the 2008
credit--according to IRS, 1.2 million taxpayers claimed the 2008 credit
for a total of $8.6 billion that must be repaid. Similarly, IRS has to
use audits to ensure taxpayers do not claim the credit for both 2008
and 2009. Because math error checks are automated and could substitute
for burdensome audits, IRS could check all returns at relatively low
cost with such authority.
Conclusions:
As part of its preparations for the 2010 filing season, IRS has the
opportunity to improve service to millions of taxpayers and reduce its
own costs by reducing electronic filing rejects and providing more
automated services. If IRS were to take advantage of these
opportunities, it may be able to reduce the volume of taxpayer phone
calls, which would improve taxpayer access to IRS assistors.
To realize maximum benefit for the 2010 filing season from its new
automated applications for authenticating electronic filers, IRS will
need to adhere to its schedule of implementation by January 18, 2010.
The beginning of the filing season is when many taxpayers file returns
electronically in order to receive their refund. Any slippage in the
schedule means that taxpayers wishing to file electronically will have
little option but to contact an IRS assistor. Missing this early window
in 2010 could also delay potential benefits to both taxpayers and IRS
of an improved authentication system for early filers until the 2011
filing season.
We also identified two opportunities for Congress to provide IRS with
additional authority to improve compliance for the 2010 filing season
and beyond and reduce its costs by extending math error authority to
cover two aspects of the first-time homebuyer tax credit. Compared to
audits, automated math error checks provide a low-cost option that may
be particularly useful as IRS confronts the challenges of ensuring
compliance with new tax law provisions.
Matters for Congressional Consideration:
In order to provide a low-cost option that helps ensure compliance with
recent legislation, we suggest that Congress consider providing IRS
with math error authority to (1) use the prior year's tax return
information to automatically verify taxpayers' compliance with the 2008
first-time homebuyer credit payback provision, and (2) ensure that
taxpayers do not improperly claim the credit in multiple years.
Recommendations for Executive Action:
We recommend that the Commissioner of Internal Revenue take the
following five actions.
* Develop and document a strategy to prevent and resolve errors causing
electronically filed returns to be rejected.
* Involve stakeholders from the paid preparer and tax software
industries in IRS's current reject working group.
* Develop an action plan for its reject working group that includes
such elements as the scope of responsibility, a plan for testing
changes, and a schedule for implementing changes.
* Provide paid preparers and software providers with clearer
descriptions of why returns are rejected.
* Implement a low-cost automated method for providing volunteer site
locations and hours of operation to taxpayers.
Agency Comments:
In commenting on a draft of this report, the IRS Commissioner for Wage
and Investment stated that based on the allotted response time that IRS
neither agrees nor disagrees with the recommendations contained in this
report.
As agreed with your offices, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 30 days
from the report date. At that time, we will send copies to the Chairmen
and Ranking Members of other Senate and House committees and
subcommittees that have appropriation, authorization, and oversight
responsibilities for IRS. We will also send copies to the Commissioner
of Internal Revenue, the Secretary of the Treasury, the Chairman of the
IRS Oversight Board, and the Director of the Office of Management and
Budget. The report also will be available at no charge on the GAO Web
site at [hyperlink, http://www.gao.gov].
If you or your staff have any questions or wish to discuss the material
in this report further, please contact me at (202) 512-9110 or at
whitej@gao.gov. Contact points for our Offices of Congressional
Relations and Public Affairs may be found on the last page of this
report. GAO staff who made contributions are listed in appendix IV.
Signed by:
James R. White:
Director, Tax Issues Strategic Issues:
[End of section]
Appendix I: Updated Slides from the September 1, 2009, Briefing:
Tax Administration: Opportunities Exist for IRS to Enhance Taxpayer
Service and Enforcement for the 2010 Filing Season:
Prepared for the Committee on Finance, U.S. Senate and the Subcommittee
on Oversight, Committee on Ways and Means, House of Representatives:
Sept. 1, 2009 (Updated):
Background:
The Internal Revenue Service‘s (IRS) preparation for the filing season,
which begins months in advance, includes: updating forms, guidance, and
processes to reflect tax law changes; hiring and training staff
including part time staff who answer telephones; and programming and
testing IRS‘s computer systems.
* IRS has been challenged in recent filing seasons with having to
implement major tax law changes, such as the stimulus-related 2008
Housing Act and 2009 Recovery Act provisions, which provided and
extended the new first-time homebuyer credit.
As of June 30, 2009, IRS received 78 million phone calls, 26 million of
which were answered by assistors. Quick access to IRS telephone
assistors contributes to accurate returns by reducing taxpayers‘
confusion about their tax obligations.
Taxpayers used paid preparers or tax preparation software to prepare 85
percent of all individual income tax returns in 2008. In addition to
preparing tax returns, these stakeholders provide advice and other
assistance to taxpayers, thus sharing the costs of administering the
tax code with IRS. Taxpayers who file electronically must do so through
such intermediaries.
As of August 14, 2009, taxpayers filed over 90 million tax returns
electronically (68 percent of all returns), which continues to expedite
refunds and save IRS resources.
IRS begins checking taxpayer compliance as it receives tax returns.
IRS‘s electronic filing system has automated validity checks to help
ensure the accuracy of returns and correct mistakes in a timely manner,
benefiting taxpayers and reducing IRS‘s costs. These automated checks
look for errors, such as incorrect Social Security numbers (SSNs) for
dependents, incorrect birth dates, and invalid zip codes, at the time
the return is submitted electronically.
* IRS automatically rejects electronic returns with these errors,
associates them with one of about 600 possible reject codes and sends
taxpayers, through their intermediaries, electronic acknowledgements
giving the error code. Taxpayers are responsible for correcting the
errors and resubmitting the returns.
* For paper returns, these validity checks are done after returns are
accepted.
After returns are accepted, IRS‘s math error program identifies
calculation errors and checks for obvious noncompliance such as claims
above income and credit limits. IRS corrects these errors during
processing, which avoids the need for audits.
Objectives, Scope, and Methodology:
Our objective was to identify opportunities for IRS to provide better
service and enhance enforcement in time for the 2010 filing season.
We analyzed IRS performance and production data, observed IRS
operations, attended IRS production meetings, reviewed Treasury
Inspector General for Tax Administration (TIGTA) and Electronic Tax
Administration Advisory Committee (ETAAC) reports, and interviewed IRS
officials and external stakeholders about performance issues and
anomalies.
We previously assessed IRS‘s filing season performance data for
reliability. We considered performance measures and data that cover the
quality,accessibility, and timeliness of IRS‘s service to be objective
and reliable based on that work.
We conducted our work at IRS headquarters in Washington, D.C. and
division and field offices, including those in Atlanta, from January
through August 2009 in accordance with generally accepted government
auditing standards.
We prepared this briefing because, in the course of our ongoing filing
season work, we identified several opportunities where immediate action
could be taken in time to improve the 2010 filing season.
Results in Brief:
IRS may be missing opportunities to improve service to taxpayers and
enhance enforcement for the 2010 filing season because it:
* lacks a strategy for preventing and resolving errors that cause
electronically filed returns to be rejected;
* does not fully leverage the expertise of paid preparers and the tax
software industry in its efforts to prevent and resolve rejected
electronically filed returns;
* does not have an action plan for implementing improvements to the
error reject codes;
* sends electronic acknowledgments to preparers and software providers
about rejected returns that are confusing and unclear;
* is developing an automated application for authenticating electronic
filers, but is not scheduled to launch it until after the date
electronic filing begins;
* lacks an automated means for helping taxpayers locate volunteer
sites; and;
* lacks math error authority to check compliance with two aspects of
the first-time homebuyer tax credit.
IRS Lacks a Strategy for Preventing and Resolving Errors That Cause
Electronically Filed Returns to Be Rejected:
According to IRS‘s September 2008 Advancing E-file study, electronic
validation aids taxpayers by helping ensure that returns are accurate,
but it can sometimes be cumbersome for taxpayers to understand and
correct errors. Paid preparers and tax software industry
representatives that we spoke with during the 2009 filing season said
this remains an issue.
While IRS has some efforts under way to make dealing with rejects less
cumbersome, IRS lacks a coordinated strategy for preventing and
resolving rejects. It lacks a documented strategy that describes, for
example, overall objectives, the role of external stakeholders,
schedules for specific actions, and needed resources. According to
ETAAC, IRS has made progress on an ad hoc basis, but addressing the
reject issue must be a permanent, structured process.[Footnote 8]
Without a strategy, IRS may be missing an opportunity to increase
electronic filing, reduce paper filing, and reduce taxpayer burden.
IRS Could Further Leverage the Expertise of External Stakeholders in
Its Efforts to Prevent and Resolve Rejects:
Tax industry representatives we spoke with said that IRS is missing
opportunities to leverage industry expertise in order to prevent and
resolve rejects. TIGTA and ETAAC have made the same point.[Footnote 9]
* Recent experience with the recovery rebate credit shows the value of
working with stakeholders. Early in the 2009 filing season, IRS
realized that millions of taxpayers were making errors claiming the
credit. IRS consulted with industry representatives to develop a
successful approach for preventing more of these errors.
Stakeholder involvement can be particularly important for agencies that
operate in a complex environment, such as tax policy, and where issues
can best be addressed by soliciting the views of stakeholders with
specialized expertise.[Footnote 10]
Without soliciting the expertise of these stakeholders, who assist 85
percent of taxpayers in filing their returns, IRS may be missing an
opportunity to better understand why rejects occur, work with
stakeholders to prevent rejects, and help taxpayers correct errors in a
less cumbersome way.
IRS Has a Working Group to Simplify Error Reject Codes, but Does Not
Have an Action Plan for Implementing Changes:
IRS has over 600 error reject codes, but they are not very useful. Of
the 600 codes, 13 account for 81 percent of all rejected electronically
filed returns. Paid preparer and software industry representatives said
that some codes are very general and cover multiple issues, while
others are so narrow that they are rarely used. IRS and TIGTA similarly
reported that the rejection codes are often not useful in determining
why the return was rejected.[Footnote 11]
IRS acknowledges that error reject codes are a problem and has
established a working group to simplify the codes. However, IRS‘s
internal working group does not include industry representatives nor at
the time we completed our work did IRS have an action plan that
included elements such as the scope of responsibility of the working
group, a plan for testing changes, and a schedule for implementing
changes.
Without such an action plan, the working group risks being less
effective and timely at developing more useful reject codes.
Electronic Acknowledgments That IRS Sends Preparers and Software
Providers About Rejects are Confusing and Unclear:
According to paid preparers and software providers, the error codes
included in IRS‘s electronic acknowledgments too often do not clearly
indicate the line on a return where an error was made or the precise
nature of the error. They said that they are unable to provide an
explanation of some error codes to taxpayers and that taxpayers must
call IRS for help.
Table 2: Common Error Reject Codes and Descriptions Sent to Paid
Preparers and Software Providers:
Error reject code number: 0029;
Description: Tax return record identification page 1 –EFIN of
originator (SEQ 0008B) must be for a valid electronic filer.
Error reject code number: 0500;
Description: Tax Form: Primary SSN (SEQ 0010) and Primary Name Control
(SEQ 0050) of the Tax Form must match data from the IRS Master File.
Error reject code number: 0502;
Description: Employer Identification Number (SEQ 0040) of Form W-2
and/or W-2GU, Payer Identification Number (SEQ 0026) of Form W-2G, and
Payer Identification Number (SEQ 0050) of Form 1099-R and Company or
Trust Identification Number (SEQ 0120) of Form 2439, and Employer EIN
(SEQ 0200) of 499R-2/W-2PR Record must match data from the IRS Master
File.
Source: IRS.
[End of table]
IRS recently placed clearer descriptions and possible solutions for 13
common electronic reject codes on its Web site. However, IRS did not
change the electronic acknowledgments. IRS officials said that IRS‘s
Modernized E-file program is supposed to provide clearer
acknowledgments, but also said that the program will not be fully
implemented until 2012.
Unclear acknowledgments create frustration for taxpayers and expense
for IRS because confused taxpayers call IRS.
Answering AGI Calls Cost IRS Millions of Dollars Because It Lacked an
Automated Method for Providing That Information:
During the 2009 filing season, taxpayers had to provide their last year‘
s adjusted gross income (AGI) or personal identification number (PIN)
to authenticate their identity in order to electronically file.
* Taxpayers who did not know their AGI or PIN and tried to get them
from IRS had to call an assistor or visit an IRS walk-in site.
As of June 30, 2009, IRS had answered 3 million calls from taxpayers
requesting their AGI, over 10 percent of the calls answered by
assistors.
Counting calls not answered, IRS received over 5 million AGI-related
calls, contributing to increased wait times. Taxpayers waited an
average of 8 minutes to be connected to an IRS assistor and millions of
taxpayers abandoned their calls or were disconnected by IRS while
waiting.
According to IRS, AGI authentication-related calls cost nearly $36
million through June 30, 2009.
IRS is Developing an Automated Application to Authenticate Electronic
Filers, but the Launch Date Is in 2010:
Although initially reluctant, in August 2009, IRS officials informed us
that they took action and were developing Web and automated telephone
applications for the 2010 filing season for taxpayers who do not have
their prior year‘s AGI or PIN. The officials said that the new
application will provide taxpayers with an alternative number that will
allow them to file electronically.
IRS officials showed us plans that included costs, milestones and a
launch date of January 18, 2010, 3 days after the date electronic
filing begins. As of August 26, 2009, the officials reported that they
were on schedule.
Meeting the launch date is important for IRS to realize the full
benefits of its efforts, since taxpayers expecting a refund tend to
file early and file electronically. Therefore, any delay could leave
taxpayers with little option but to call IRS and speak with an
assistor.
Successful implementation in time for the 2010 filing season has the
potential to significantly reduce the burden on IRS‘s telephone
assistors and improve taxpayer service. However, IRS has just begun
developing these applications, testing is scheduled to continue up to
the launch date, which is just after electronic filing begins, and
there is no time for schedule slippage.
Taxpayers Seeking Information from IRS on the Location and Hours of
Volunteer Sites Must Speak to an IRS Assistor:
Taxpayers contacting IRS for the location and hours of the 12,000
volunteer sites must speak to an IRS assistor.
* Assistors have a list of volunteer site locations and hours that is
updated twice a week. However, that information is not on IRS‘s Web
site, which directs taxpayers to call IRS.
* Although IRS reported receiving a relatively small number of such
calls”60,000 as of June 30”the calls do add to IRS‘s telephone queues.
Even at half of the average assistor cost per call of $25.75 this is
nearly $800,000 a year to answer such calls.
IRS does post location information for its Super Saturdays, 1-day
events that provide tax assistance at hundreds of sites across the
country, on its Web site, IRS.gov.
Although IRS has plans to provide a zip code locator as part of a
future redesign of its Web site, that redesign has yet to be funded. In
the meantime, low-cost options, such as posting IRS‘s existing list of
volunteer sites and hours on IRS.gov, could eliminate some calls to
assistors.
IRS Lacks Math Error Authority for Ensuring Compliance with Two Aspects
of the First-Time Homebuyer Tax Credit:
Currently, IRS has to use labor-intensive, expensive audits to check
compliance with the new first-time home homebuyer tax credit resulting
from 2008 and 2009 legislation. Two aspects of the credit lend
themselves to an automated approach.
* One is the requirement that the 2008 credit be repaid in increments
of up to $500 per taxpayer for 15 years beginning in 2011. IRS
estimates that 1.2 million taxpayers claimed the 2008 credit for a
total of approximately $8.6 billion.
* The other is that a taxpayer cannot claim the first-time homebuyer
credit in both 2008 and 2009.
The number of taxpayers claiming the credit and the amounts at risk per
taxpayer mean that auditing every credit claimed may not be cost-
effective.
IRS lacks math error authority, which must be provided by statute, to
use taxpayers‘ prior year return information to check for compliance
with these two provisions. Math error checks are suitable for checking
compliance with these provisions because, for many tax returns, the
requirement to repay and violations of the limit on multiple claims
will be obvious from the prior year‘s return. Because math error checks
are automated, with this authority, IRS could check all returns at
relatively low cost.
Conclusion:
As IRS prepares for the 2010 filing season, it has opportunities to
improve service to millions of taxpayers and reduce its own operating
costs by reducing electronic filing reject rates and providing more
automated services. If IRS were to take advantage of these
opportunities, it may be able to reduce the volume of taxpayer phone
calls, which would improve taxpayer access to IRS assistors.
To realize maximum benefit for the 2010 filing season from its new
automated application for authenticating electronic filers, IRS will
need to adhere to its implementation date of January 18, 2010. The
beginning of the filing season is when many taxpayers file returns
electronically in order to receive their refund. Any slippage in the
schedule means that taxpayers wishing to file electronically will have
little option but to contact an IRS assistor. Missing this early window
in 2010 could also delay the potential benefits to both taxpayers and
IRS of an improved authentication system for early filers until the
2011 filing season.
We also identified two opportunities for Congress to provide IRS with
additional authority to improve compliance for the 2010 filing season
and beyond and reduce its costs by extending math error authority to
cover two aspects of the first-time homebuyer tax credit. Compared to
audits, automated math error checks provide a low-cost option that may
be particularly useful as IRS confronts the challenges of ensuring
compliance with new tax law provisions.
Matters for Congressional Consideration:
Given the potential for improving compliance for the next filing season
and beyond, the Congress should consider providing IRS with math error
authority to use prior years‘ tax return information to automatically:
* verify taxpayers‘ compliance with the 2008 first-time homebuyer
credit payback provision and;
* ensure that taxpayers do not improperly claim the credit in multiple
years.
Recommendations for Executive Action:
The Commissioner of Internal Revenue should ensure that IRS:
1. develops and documents a strategy to prevent and resolve errors
causing electronically filed returns to be rejected;
2. involves stakeholders from the paid preparer and tax software
industries in its current reject working group;
3. develops an action plan for its reject working group that includes
such elements as the scope of responsibility, a plan for testing
changes, and a schedule for implementing changes;
4. provides paid preparers and software providers with clearer
descriptions of why electronically filed returns are rejected; and;
5. implements a low cost automated method for providing volunteer site
locations and hours of operation to taxpayers.
[End of section]
Appendix II: Most Common Error Reject Codes in the 2009 Filing Season
and IRS Descriptions:
Of the more than 600 possible error reject codes that the Internal
Revenue Service (IRS) sent to taxpayers attempting to file
electronically during the 2009 filing season, table 1 lists 15 of the
most common. These error codes accounted for 85 percent of all error
reject codes included in the electronic acknowledgments received by
taxpayers through paid preparers and software providers.
Table 1: Most Common Error Reject Codes and IRS Descriptions for the
2009 Filing Season:
Error reject code: 0679;
IRS explanations of error reject codes contained in electronic
acknowledgments[A]: Authentication Record - When the PIN TYPE Code (SEQ
0008) equals "S" or "O", the Primary Prior Year Adjusted Gross Income
(SEQ 0020) or Primary Prior Year PIN (SEQ 0025) must match the Primary
Prior Year Adjusted Gross Income or Primary Prior Year PIN on the IRS
Master File;
Clearer description found on IRS's Web site: The primary taxpayer's or
spouse's Prior Year Adjusted Gross Income (Prior Year AGI) or the Prior
Year PIN entered on the Authentication Record does not match the
original Prior Year AGI or Prior Year PIN entered on Form 8879, IRS e-
file Signature Authorization;
Percentage of error incidences: 19.7;
Cumulative percentage: 19.7.
Error reject code: 0504;
IRS explanations of error reject codes contained in electronic
acknowledgments[A]: Dependent's SSN (SEQ 0175, 0185, 0195, 0205) of
Form 1040/1040A and corresponding Dependent Name Control (SEQ 0172,
0182, 0192, 0202) must match data from the IRS Master File. Qualifying
Child SSN (SEQ +0175, 0185, 0195, 0205) of Form 1040-SS (PR) and
corresponding Qualifying Child Name Control (SEQ +0172, 0182, 0192,
0202) must match data from the IRS Master File;
Clearer description found on IRS's Web site: The last name of the
dependent on the return does not match the IRS Master File and/or SSA
records. This could be caused by misspelling the last name or using the
wrong SSN. It can also result if the dependent has multiple or
hyphenated last names;
Percentage of error incidences: 9.1;
Cumulative percentage: 28.8.
Error reject code: 0269b;
IRS explanations of error reject codes contained in electronic
acknowledgments[A]: Form 1040/1040A/1040EZ - Recovery Rebate Credit
(SEQ 1220) cannot be claimed because the maximum amount has already
been received based on the information contained on the 2007 tax
return; Clearer description found on IRS's Web site: NA;
Percentage of error incidences: 8.1;
Cumulative percentage: 36.9.
Error reject code: 0502;
IRS explanations of error reject codes contained in electronic
acknowledgments[A]: Employer Identification Number (SEQ 0040) of Form W-
2 and/or; W-2GU, Payer Identification Number (SEQ 0026) of Form W-2G,
and Payer Identification Number (SEQ 0050) of Form 1099-R; and Company
or Trust Identification Number (SEQ 0120) of; Form 2439, and Employer
EIN (SEQ 0200) of 499R-2/W-2PR Record must match data from the IRS
Master File. Note: Form 1099-R is ONLY required when federal income tax
is withheld;
Clearer description found on IRS's Web site: The Employer
Identification Number (EIN) of the business reported on Form(s) W-2, W-
2G, W-2GU, 499R-2/W-2PR, 1099R, or 2439 must match the EIN on the IRS
Master File. This error could be caused by entering the EIN incorrectly
or using an EIN that is invalid;
Percentage of error incidences: 6.1;
Cumulative percentage: 43.0.
Error reject code: 0522;
IRS explanations of error reject codes contained in electronic
acknowledgments[A]: Primary Date of Birth (SEQ 0010) in the
Authentication Record of an Online Return does not match data from the
IRS Master File;
Clearer description found on IRS's Web site: The Date of Birth (DOB) of
the primary taxpayer (ERC 0522) or spouse (ERC 0523) does not match the
IRS Master File. The DOB is required to authenticate the taxpayer's
Self-Select PIN which acts as the taxpayers' signature when filing an
online return;
Percentage of error incidences: 5.8;
Cumulative percentage: 48.8.
Error reject code: 0507;
IRS explanations of error reject codes contained in electronic
acknowledgments[A]: Dependent's SSN (SEQ 0175, 0185, 0195, 0205) of
Form 1040/1040A was previously used for the same purpose;
Clearer description found on IRS's Web site: The dependent's SSN
claimed on the tax return and/or Schedule EIC has been used on another
tax return. This could be the result of an inadvertent data entry error
or someone else has claimed this dependent;
Percentage of error incidences: 5.7;
Cumulative percentage: 54.5.
Error reject code: 0500;
IRS explanations of error reject codes contained in electronic
acknowledgments[A]: Primary SSN (SEQ 0010) and Primary Name Control
(SEQ 0050) of the Tax Form must match data from the IRS Master File;
Clearer description found on IRS's Web site: The last name for the
primary taxpayer on the return does not match what the IRS and/or the
Social Security Administration (SSA) have on file. This could be caused
by misspelling the primary taxpayer's last name or using the wrong SSN
for the primary taxpayer. It can also result if the primary taxpayer
has multiple or hyphenated last names, or has changed their last name
(e.g., by marriage or court order) and has not notified SSA;
Percentage of error incidences: 5.4;
Cumulative percentage: 59.9.
Error reject code: 0501;
IRS explanations of error reject codes contained in electronic
acknowledgments[A]: Qualifying SSN (SEQ 0015, 0085) of Schedule EIC and
the corresponding Qualifying Child Name Control (SEQ 0007, 0077) must
match data from the IRS Master File;
Clearer description found on IRS's Web site: The SSN and last name
entered for the qualifying child does not match what the IRS and/or SSA
have on file. The qualifying SSN of the dependent on Schedule EIC,
Earned Income Credit, must match data from the IRS Master File. This
could be a companion error code to Reject Code 0504. If the child does
not qualify as a dependent, the child is not eligible to be a
qualifying child for EIC;
Percentage of error incidences: 4.5;
Cumulative percentage: 64.4.
Error reject code: 0680;
IRS explanations of error reject codes contained in electronic
acknowledgments[A]: Authentication Record - When the PIN TYPE Code (SEQ
0008) equals "S" or "O" and the Filing Status (SEQ 0130) is "2"
(Married Filing Jointly) on the return, the Spouse Prior Year Adjusted
Gross Income (SEQ 0050) or Spouse Prior Year PIN (SEQ 0055) must match
the Spouse Prior Year Adjusted Gross Income or Spouse Prior Year PIN on
the IRS Master File;
Clearer description found on IRS's Web site: The primary taxpayer's or
spouse's Prior Year Adjusted Gross Income (Prior Year AGI) or the Prior
Year PIN entered on the Authentication Record does not match the
original Prior Year AGI or Prior Year PIN entered on Form 8879, IRS e-
file Signature Authorization;
Percentage of error incidences: 4.4;
Cumulative percentage: 68.8.
Error reject code: 0510;
IRS explanations of error reject codes contained in electronic
acknowledgments[A]: Primary SSN (SEQ 0010) and/or Secondary SSN (SEQ
0030) where the SSN was claimed as an exemption (SEQ 0160) and/or (SEQ
0163) on the return and was also used as a Dependent's SS Non Form 1040
or Qualifying Child on Form 1040-SS(PR) (SEQ 0175, 0185, 0195, 0205)on
another return. Dependent's SSN (SEQ 0175, 0185, 0195, 0205) was used
as a Primary SSN (SEQ 0010) or Secondary SSN (SEQ 0030) on another
return and was claimed as an exemption (SEQ 0160) on that return;
Clearer description found on IRS's Web site: Normally, this error is
the result of a child submitting their own tax return and claiming
their own exemption. When the parent(s) file and claim the child as a
dependent, the parents' return will reject with ERC 0510. Example 1: A
college student submits their own return and fails to indicate that
they can be claimed as a dependent on another return. When the parents
submit their return after the student has filed, and attempts to claim
the student as a dependent, the return will reject. Example 2: A newly
married couple files a joint return. When the parents submit their
return after the couple has filed, and attempt to claim their daughter
as a dependent, the return will reject. Using an incorrect SSN may also
cause this error if the erroneous SSN matches another taxpayer or
dependent;
Percentage of error incidences: 4.0;
Cumulative percentage: 72.9.
Error reject code: 0503;
IRS explanations of error reject codes contained in electronic
acknowledgments[A]: Secondary SSN (SEQ 0030) and Spouse's Name Control
(SEQ 0055) of the Tax Form must match data from the IRS Master File;
or; If filing status (SEQ 0130) equals "4" and Exempt Spouse (SEQ 0163)
equals "X", then the Spouse SSN (SEQ 0030) and Exempt Spouse Name
Control (SEQ 0165) must match data from the IRS Master File;
Clearer description found on IRS's Web site: The last name for the
secondary taxpayer on the return does not match the IRS Master File
and/or SSA records. This can be caused by misspelling the last name or
using the wrong SSN. It can also result if the spouse has multiple or
hyphenated last names, or has changed their last name (e.g., marriage
or court order) and has not notified the SSA;
Percentage of error incidences: 3.5;
Cumulative percentage: 76.3.
Error reject code: 0515[B];
IRS explanations of error reject codes contained in electronic
acknowledgments[A]: Primary SSN (SEQ 0010) was used as a Primary SSN
more than once;
Clearer description found on IRS's Web site: NA;
Percentage of error incidences: 2.8;
Cumulative percentage: 79.1.
Error reject code: 0506;
IRS explanations of error reject codes contained in electronic
acknowledgments[A]: Schedule EIC - Qualifying SSN (SEQ 0015, 0085) of
Schedule EIC was previously used for the same purpose;
Clearer description found on IRS's Web site: The qualifying child's SSN
listed for the purpose of claiming EIC has been used on another tax
return. This could be the result of an inadvertent data entry error or
someone else has claimed this dependent. This is often a companion to
Reject Code 0507. The qualifying child for EIC purposes must be a
qualifying dependent;
Percentage of error incidences: 2.4;
Cumulative percentage: 81.5.
Error reject code: 0523;
IRS explanations of error reject codes contained in electronic
acknowledgments[A]: Spouse Date of Birth (SEQ 0040) in the
Authentication Record of an Online Return does not match data from the
IRS Master File;
Clearer description found on IRS's Web site: The Date of Birth (DOB) of
the primary taxpayer (ERC 0522) or spouse (ERC 0523) does not match the
IRS Master File. The DOB is required to authenticate the taxpayer's
Self-Select PIN which acts as the taxpayers' signature when filing an
online return;
Percentage of error incidences: 1.9;
Cumulative percentage: 83.4.
Error reject code: 0535;
IRS explanations of error reject codes contained in electronic
acknowledgments[A]: Schedule EIC - Qualifying SSN (SEQ 0015, 0085) of
Schedule EIC and the corresponding Year of Birth (SEQ 0020, 0090) must
match data received from the Social Security Administration;
Clearer description found on IRS's Web site: The year of birth for the
qualifying child does not match what the IRS and/or SSA have on file.
The qualifying SSN of the dependent on Schedule EIC, Earned Income
Credit, must match data from the IRS Master File;
Percentage of error incidences: 1.8;
Cumulative percentage: 85.2.
Error reject code: Total of all other error reject codes;
Percentage of error incidences: 14.8;
Cumulative percentage: 100.
Source: GAO analysis of IRS data.
Note: Data are from January 1, 2009 through August 19, 2009.
[A] Exceptions not shown.
[B] Error Reject Code does not have a simplified description on IRS's
Web site.
[End of table]
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
GAO Contact:
James R. White, (202) 512-9110 or whitej@gao.gov:
Acknowledgments:
In addition to the contact named above, Joanna M. Stamatiades,
Assistant Director; Vida Awumey, John Dell'Osso, Kara Eusebio, Melanie
Helser, Lina Khan, Kirsten B. Lauber, Angela Leventis, Natalie Maddox,
Karen V. O'Conor, Neil A. Pinney, and Sabrina C. Streagle made key
contributions to this report.
[End of section]
Footnotes:
[1] Most taxpayers filed their 2008 tax returns from January 1 to April
15, 2009, which is the deadline for filing individual income tax
returns. For the 2009 filing season, IRS began accepting electronic
returns on January 16. However, millions of taxpayers receive
extensions from IRS, which allowed them to delay filing until as late
as October 15.
[2] Over the years, Congress granted IRS legal authority to cover 11
areas through its math error authority so the agency could correct
return errors during processing, including calculation errors and
entries that are inconsistent or exceed statutory limits. If it is not
specified in the statute, IRS cannot pursue assessment and collection
activities without issuing a statutory notice of deficiency. IRS was
granted math error authority in 26 U.S.C. § 6213(b) and it can only be
used as specified in 26 U.S.C. § 6213(g)(2). An example of a math error
correction would be where IRS can automatically correct a return by
disallowing a child tax credit if the filer fails to provide the
correct taxpayer identification number. Prompt compliance checks are
important because as unpaid taxes age, the likelihood of collecting all
or part of the amount owed decreases.
[3] GAO, Tax Administration: Interim Results of IRS's 2009 Filing
Season, [hyperlink, http://www.gao.gov/products/GAO-09-640]
(Washington, D.C.: June 3, 2009). IRS answered 23 million calls through
its automated service and nearly 23 million taxpayers abandoned their
calls, received busy signals, or were disconnected by IRS.
[4] Economic Stimulus Act of 2008, Pub. L. No 110-185, 122 Stat. 613
(2008).
[5] Housing and Economic Recovery Act of 2008, Pub. L. No. 110-289, 122
Stat. 2654 (2008).
[6] American Recovery and Reinvestment Act of 2009, Pub. L. No. 111-5,
123 Stat. 115 (2009). While many of the provisions of the two credits
are the same, a major difference is that the 2008 first-time homebuyer
credit has to be paid back over a 15-year period, while the 2009 credit
does not.
[7] As we have reported, the number of returns they prepare and the
advice and support paid preparers and software companies provide to
taxpayers make these intermediaries a critical component in the tax
system. See, for example, GAO, Tax Administration: Many Taxpayers Rely
on Tax Software and IRS Needs to Assess Associated Risks, [hyperlink,
http://www.gao.gov/products/GAO-09-297] (Washington, D.C.: Feb. 25,
2009), and Tax Preparers: Oregon's Regulatory Regime May Lead to
Improved Federal Tax Return Accuracy and Provides a Possible Model for
National Regulation, [hyperlink,
http://www.gao.gov/products/GAO-08-781] (Washington, D.C.: Aug. 15,
2008).
[8] Electronic Tax Administration Advisory Committee, Annual Report to
Congress(Lanham, Md., June 2009).
[9] Treasury Inspector General for Tax Administration, A Self-
assistance Option Would Reduce Burden and Costs Associated with
Resolving Rejected Electronic Tax Returns, Reference No. 2007-40-128
(Washington, D.C.: June 17, 2008).
[10] GAO, Agencies‘ Strategic Plans Under GPRA: Key Questions to
Facilitate Congressional Review, [hyperlink,
http://www.gao.gov/products/GAO/GGD-10.1.16] (Washington, D.C.: May
1997).
[11] See Internal Revenue Service, Advancing E-file Study, Phase 1
Report, Document Number 0206.0210, Sept. 30, 2008).
[End of section]
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