Automated OIC Appeal Review

Did you know that if your Offer in Compromise (OIC) is rejected, there is a “self-help tool” on the IRS website that will walk you through a series of steps to help you determine if you should appeal it or not?

This is yet another example of the IRS’ attempt to automate everything they do.  I guess it does make sense to explore all available options for replacing the best and brightest who will be leaving the IRS when they retire.  And I guess it makes sense to try to find cheaper alternatives, given that the IRS is not going to get the kind of funding they need to hire live bodies.  This just seems to cross the line.

I know how complicated and frustrating the OIC process can be.  When an OIC has been rejected, what the appellant really needs is to speak with a good tax attorney.  Or, at a minimum, he needs to be able to talk with a live body at the IRS who will explain the IRS’ determination and who will really consider a taxpayer’s individual circumstances.

It does have some value, don’t get me wrong.  I have spent a little time with this tool and, from what I can tell, it is perfect for identifying errors and oversights made by offer examiners.

Should the IRS Take to the Phones?

When the Taxpayer Advocate Service (TAS) submitted its 2011 annual report to Congress, it emphasized how “the IRS has changed from focusing on personal, local service to automated, centralized processes” and how this shift has hurt the taxpaying public. At least one author has taken this to mean that the IRS might be more effective in its collection efforts if it would pick up the phone and call taxpayers, particularly in the early stages of collections. See “Personal Finance: IRS Calls to Delinquent Taxpayers?” by Susan Tompor.

First, I’m not sure this was what the TAS had in mind.

Second, I’m not sure this is what we would want.

1. The problem with automated processes is that mistakes are common. Taxpayers are people and real people have real, sometimes unique tax problems that computers and automated letters/processes don’t always recognize. This results in delays and issues with fairness, which in turn results in distrust of the IRS. This is the concern that Nina Olson and the TAS has been harping on for years. While TAS is certainly pushing for an IRS with a more human element, I don’t think TAS is recommending they call everyone as soon as they incur a new tax debt.

2.  As Ms. Tompor correctly points out, with identity theft so rampant these days, few people would be comfortable speaking with a caller who purports to be from the IRS and who wants them to provide information such as their social security number, for verification purposes. I think this would be a waste of IRS resources. And while a phone call can be cheaper than the cost of postage, the phone calls would not replace the letters. Knowing the IRS, a confirming letter would have to be mailed after each call confirming the contact and the content of the conversation.

I am definitely in Nina Olson’s corner when it comes to making IRS interaction more helpful and individualized. But there is a time and place for everything, and I don’t think phone calls on standard collection cases are necessary or desirable.