10.5.7  Use of Pseudonyms by IRS Employees  (11-19-2010)
Introduction to the Use of Pseudonyms by IRS Employees

  1. The IRS is committed to the personal safety of its employees. This IRM explains the steps needed to acquire a pseudonym to assure IRS employees have the necessary protection to their personal safety and the prevention of harm or danger to themselves and their families.

  2. This IRM updates and supersedes the previous IRM 1.2.4, "Use of Pseudonyms by IRS Employees" and contains new information, guidance, and procedures for all Service managers and employees who may request the use of a pseudonym. The IRM provides guidance based on the passage of the IRS Restructuring and Reform Act of 1998 on July 22, 1998 (RRA 98).

  3. Section 3706 of RRA 98 authorizes the use of pseudonyms by IRS employees. Listed below are some of the guidelines, requirements and conditions of having a pseudonym:

    1. Employees who used pseudonyms before the enactment of RRA 98, Section 3706 were "grandfathered" in under the statute.

    2. Section 3706 authorizes the use of pseudonyms by IRS employees only if adequate justification for the use is provided by the employee and its use is approved by the employee's manager.

    3. Prior to RRA 98 Section 3706, the use of pseudonyms by IRS employees was permitted if the employee believed he or she could be identified by his or her last name so as to warrant the use of a pseudonym. Further, no managerial approval was required. It was only required that the pseudonym be registered with the employee's manager.

    4. Section 3706 of RRA 98 is meant to eliminate the taxpayer perception that IRS employees avoid accountability for their actions through the use of pseudonyms, while still protecting an employee's right to use pseudonyms in appropriate circumstances.

    5. The employee's manager must approve use of the pseudonym prior to its use. Requests to use pseudonyms that do not provide adequate justification will be denied on that basis.

    6. See Exhibit 10.5.7-1 for the text of Section 3706 (RRA 98) from 26 USC 7804.  (11-19-2010)
Definitions of Terms

  1. This subsection contains the definition of terms as used in the context of Section 3706 of RRA 98.  (11-19-2010)
What is a Pseudonym?

  1. A Pseudonym is a fictitious name.  (11-19-2010)
What is Protection of Personal Safety?

  1. Protection of personal safety is keeping one’s self or others from harm or danger. Reasons for concern for personal safety include:

    1. Verbal and written threats of bodily harm or injury from a taxpayer or his or her representative directly involved in a case under review

    2. Actual bodily harm or injury from a taxpayer or his or her representative

    3. Harassment

    4. Taxpayer or his or her representative contacts an employee or employee's family member at his or her home without purpose of legitimate communication

    5. Evidence of taxpayer or representative aggression towards any government employee

    6. Employee’s concern about personal safety based on a taxpayer's or his or her representative’s threatening or aggressive acts against any other employee in the same or similar position or same or similar business unit  (11-19-2010)
Reporting to TIGTA

  1. Employees have a responsibility to refer to TIGTA all assaults or threats to themselves or members of his or her family by a taxpayer or the taxpayer's representative.  (11-19-2010)
What is Harassment?

  1. Harassment is the use of words, gestures, or actions that tend to alarm, disturb, or abuse another person.  (11-19-2010)
What is Adequate Justification?

  1. Adequate justification is defined as either of the following:

    1. Credible evidence that establishes that a taxpayer or his or her representative engaged in physically, financially, or emotionally threatening activity, including but not limited to:

      • Committing a battery against the employee, including unwanted touching

      • Intimidating or attempting to intimidate the employee, such as with a show of weapons

      • Uttering statements or specific threats of bodily harm directed to the employee

      • Assaulting the employee

      • Making statements threatening financial harm to the employee

      • Harassing the employee

      • Contacting an employee at his or her home

      • Committing the acts set forth above against members of the employee’s family

      • Committing the acts set forth in the above against another employee and the requesting employee has been assigned a case involving the same taxpayer

    2. Situations where an employee’s job or place of duty exposes him or her to an increased risk to personal safety or that of their family. This increased risk may be due to, but not limited to, any of the following:

      • A locator service shows the taxpayer, whose case the employee has been assigned, has a violent criminal history that would suggest a heightened risk of harassment toward an employee.

      • The employee is expected to encounter taxpayers or representatives who are active members of groups that advocate violence against IRS or other federal employees.

      • The employee is expected to encounter taxpayers who have been reported to have engaged in activities that physically, financially, or emotionally threaten or harm any other federal, state, county, or local government employee.  (11-19-2010)
Documentation of Credible Evidence

  1. Documentation of credible evidence includes, but is not limited to, the examples listed below:

    1. Signed statement by employee, family member(s) or witness, or a letter signed by the taxpayer or his or her representative which demonstrates any of the above noted criteria under adequate justification

    2. A document from a financial institution showing that a taxpayer has tried to place liens on an employee's assets  (11-19-2010)
Protecting Taxpayer-Specific Information Designated as IRC 6103 Material

  1. Any taxpayer-specific information submitted to justify the request for a pseudonym remains the return information of the taxpayer and must be protected under the provisions of Internal Revenue Code (IRC) section 6103. Any return information included with the application should be specifically designated as IRC 6103 material.  (11-19-2010)
Procedures for Requesting a Pseudonym

  1. The following procedures must be used regarding the request and approval of pseudonyms by IRS employees:

    1. Employees will submit their requests for pseudonyms to their manager via either encrypted E-mail or hard copy in a confidential envelope. Employee requests must provide adequate justification for the use of a pseudonym related to the protection of personal safety.

    2. Employees' requests for the use of pseudonyms will include the pseudonym that they choose to use. Use the guidance described below when choosing a pseudonym:

      • Choose a common surname (last name).

      • In rare cases, where the legal first name is unique to the point of compromising the employee's identity, a first name may also be chosen.

      • Pseudonym initials can be consistent with real name initials.

      • Choose a name with which the employee is comfortable and which may be easily remembered.


  2. Employees requesting the use of a pseudonym will not be able to utilize the pseudonym until notified that the request was approved by management or as a part of a resolution to the employee’s grievance. The employee must also wait until confirmation is received from the Office of Privacy Compliance that the pseudonym has been added to Outlook and Discovery Directory.

  3. An employee who receives an approved pseudonym must use it in the performance of all official duties during his or her hours of work. Should a pseudonym be compromised, the employee can request a replacement pseudonym without need for establishing adequate justification, as approval was previously given by the appropriate manager.

  4. Documentation of pseudonym approvals will be maintained in employees' drop files.  (11-19-2010)
When the Manager Approves the Use of a Pseudonym

  1. If the manager approves the employee's request for the use of a pseudonym, the manager needs to register the pseudonym with the Office of Privacy Compliance. The manager will forward the request using encrypted E-mail to the Office of Privacy Compliance at *Pseudonym or pseudonym@irs.gov. The manager must include the following information within the E-mail:

    • Legal name of the employee

    • Chosen pseudonym of the employee

    • Employee's SEID

  2. Within three business days from receipt of the request, the manager will inform the employee that the pseudonym request is approved with instructions that the employee must not begin using the pseudonym until advised by the Office of Privacy Compliance that the change from his or her legal name to a pseudonym has been made within Outlook and the Discovery Directory.

  3. Once employees begin using their pseudonyms, managers will be responsible for insuring that the pseudonyms are shared with the employees' co-workers so that they do not address or refer to the pseudonym holders by their legal name, revealing their identity to taxpayers. Organizational listings of employees must also be updated to show only the pseudonym.

  4. A pseudonym stays with an employee for the duration of his or her IRS career, unless the employee determines he or she no longer requires one.  (11-19-2010)
When the Manager Disapproves the Use of a Pseudonym

  1. If the employee's request is disapproved, within three business days from receipt of the request, the manager must return the request to the employee for additional justification. The manager must provide, in writing, the reason(s) for disapproval. The manager must also advise the employee, in writing, that they have five business days to provide the additional information. This can be done via encrypted E-mail or hard copy in a confidential envelope.

  2. The employee will then have five business days from receipt of the disapproval, excluding absences from work, to provide additional written adequate justification to his or her manager.

  3. Upon receipt of the additional justification, the manager will have three business days to review the request.

  4. If the second request is approved, the manager will follow the guidance provided above in (1) and (2).

  5. If the manager disapproves the request a second time, it will be returned to the employee, in writing. The manager will provide the employee information that they have 3 days to submit their request to the next level of management.

  6. The employee will then have the option within three business days, excluding absences from work, to provide additional justification and submit the request to the appropriate next level manager.

  7. The next level manager will have three business days to review the request and approve or disapprove it. If disapproved at this level, the employee may file a grievance under terms of Article 41 of the National Agreement for bargaining unit employees, or utilize agency grievance procedures for non-bargaining unit employees.  (11-19-2010)
Office of Privacy Compliance Responsibilities

  1. The Office of Privacy Compliance will process all requests for pseudonyms received by the manager of record within 14 business days.

  2. A copy of the encrypted E-mail documenting the approval of a request for a pseudonym will be maintained by the Office of Privacy Compliance.

  3. The Office of Privacy Compliance will be responsible for managing and maintaining the official Pseudonym Master List and all other related files where pseudonym information will be stored. The Office of Privacy Compliance will insure that all information pertaining to pseudonym holders will be maintained in a secured manner consistent with IRS security and privacy policy requirements.

  4. The Pseudonym Master List will be updated each month to ensure that the information is correct.

  5. Visit the Office Of Privacy, Information Protection and Data Security Pseudonym Website for up-to-date information regarding the IRS Pseudonym program at: http://irweb.irs.gov/AboutIRS/bu/pipds/pip/privacy/pseudonym/default.aspx.  (11-19-2010)
Procedures for Withdrawal or Removal from the Pseudonym Program

  1. The following procedures must be used regarding the withdrawal from the Pseudonym program by IRS employees:

    1. When an employee no longer desires a pseudonym, the employee must notify his or her manager via either encrypted E-mail or hard copy in a confidential envelope.

    2. If the manager receives such notification, or when the pseudonym holder separates from the IRS, the manager must then send an encrypted E-mail to the Office of Privacy Compliance at *Pseudonym or pseudonym@irs.gov stating that the employee no longer requires a pseudonym. The manager must include the employee's legal name, the employee's assigned pseudonym, the employee's SEID, and the reason for withdrawal from the program.

    3. The Office of Privacy Compliance will perform the necessary steps to remove the employee's pseudonym records from the Pseudonym Master List, and request that pseudonyms be removed from IRS directories.


    Employees should not contact the Employee Resource Center (ERC) or the IRS Help Desk to withdraw from the pseudonym program. Employees should submit their request through their manager to the Office of Privacy Compliance at the pseudonym@irs.gov mailbox.  (11-19-2010)
Pseudonym Guidance for Employees who are Authorized to Carry a Pocket Commission

  1. Employee will be provided with a pocket commission in the employee's approved pseudonym per the instructions found in IRM, Use of Pseudonyms on Pocket Commission.

  2. Please note that IRM (5) states that "Pocket Commissions issued in a registered pseudonym may not be used as retirement mementos, for honorary presentations, or for similar purposes. These commissions must be recovered and destroyed."  (11-19-2010)
When to Use Unique Identifying Number

  1. RRA 98 Section 3705(a) provides identification requirements for all IRS employees (including employees with a pseudonym) working tax related matters.

  2. IRS employees (including pseudonym holders) are required to give their name, and unique identification number (badge number), during taxpayer telephone, face to face, and written contact. In addition, a telephone number is required on all taxpayer correspondence. This will provide taxpayers with enough information to identify an IRS employee who may have previously assisted with tax related matters.

  3. The term "ID Card Number" refers to an employee's badge number only. It should not be construed to be the employee's enforcement shield or pocket commission number.

  4. Employees who have a request for a pseudonym approved will be given a new Legacy ID Card with a new ten-digit ID number. Once negotiations are complete on HSPD-12, pseudonym Legacy Cards will be replaced with pseudonym HSPD-12 Smart Cards.

  5. On manually generated and handwritten correspondence, employees with an approved pseudonym must use their pseudonym name and generated Integrated Data Retrieval System (IDRS) or other unique letter system number. If an IDRS/unique letter system number is not generated, use of an employee's unique identifying number is required.

  6. While reviewing taxpayer correspondence and observing employee telephone or in-person contacts with taxpayers or taxpayers' representatives, managers must ensure that the employee name (approved pseudonym) and generated IDRS/unique letter system number, or unique identifying number, are properly used.

  7. When attempting to locate a specific employee at the insistence of the taxpayer or the taxpayer's representative, managers must ensure that only the approved pseudonym used by the Service employee is disclosed.  (11-19-2010)
IRS Systems of Records Notice That Pertain to the Use of Pseudonym Name Lists

  1. Pseudonym lists are included in the IRS system of records, General Personnel and Payroll Records, Treasury/IRS 36.003, and must be treated accordingly for disclosure purposes.  (11-19-2010)
Pseudonym Holders, the Courts and Legal Matters

  1. Sworn documents and/or any other document filed with any court, including but not limited to affidavits used in connection with enforcing summonses and obtaining writs of entry, may only be signed with the approved pseudonym if the document states that it is signed using a pseudonym. Absent such a statement, the document must be signed using the declarant's legal name and should be filed with the court as a sealed document.

  2. Employees testifying in court must use their legal name unless, prior to giving testimony, the court has been informed and consented to the employee's use of the approved pseudonym.

  3. The signing of sworn documents or any other document filed with any court and the testimonial use of pseudonyms will require close coordination with the appropriate Chief Counsel office.  (11-19-2010)
Sensitive Nature of Pseudonyms

  1. Employees who use an approved pseudonym must use it with all internal and external contacts, and will not be permitted to change back and forth between their pseudonym and legal name.

  2. Once the employee begins using the approved pseudonym, the manager must ensure that the employee's co-workers and associates are informed of the pseudonym, and explain that all employees must use the pseudonym when speaking of or to the employee.

  3. Managers of pseudonym holders must ensure that office documents including team listings, organization charts, and telephone directories are updated to reflect each employee's pseudonym.

  4. Managers and employees who work with a pseudonym holder must never reveal the legal name of the pseudonym holder to anyone internally or externally.

  5. Managers and employees who work with a pseudonym holder must introduce the pseudonym holder by the pseudonym name, not his or her legal name, in all situations.  (11-19-2010)
Effects of Pseudonym Requirements on Other IRMs

  1. IRMs for Services and Enforcement and Operations Support that may impact pseudonym holders must be updated to comply with the provisions of RRA 98, Section 3706, and the provisions of this IRM.  (11-19-2010)
Assignment of Work to Pseudonym Holders

  1. Casework, and all other work, that could compromise the legal identity of a pseudonym holder, will not be assigned to the pseudonym holder. For example, a customer service representative, revenue agent or other employee who is a pseudonym holder, would not be assigned a case in which the taxpayer was already aware of the employee's legal name due to a previous case.  (11-19-2010)
Pseudonym Holders Official Travel

  1. Pseudonym employees are allowed to acquire an agency credit card in the pseudonym name.

  2. The pseudonym credit card can be used for all official travel, including union travel for approved union training, as that is also official time approved by the agency. In such cases, pseudonym employees are still required to comply with the Government bank card provisions regarding timely payments on the credit card.

  3. Employees are required to use their legal name when purchasing airline tickets .  (11-19-2010)
Communications With and About Pseudonym Holders

  1. Just as pseudonym employees must use their pseudonym for all official purposes, all agency employees and managers must correspond and converse with, or about, pseudonym employees using only the employees' pseudonyms.

  2. The only exceptions are pertinent personnel matters (e.g. payroll). For example, employee lists, including E-mail distribution lists, to, or about, pseudonym employees must include pseudonyms rather than employees' legal names. Otherwise, pseudonym employees' legal identities could ultimately be compromised.  (11-19-2010)
Mismatched Pseudonym Holder Names

  1. To ensure pseudonym names are properly used by all IRS employees, other than for pertinent personnel matters, employee name lists and distribution lists should be acquired from Discovery Directory only. Information acquired from personnel systems such as HR Connect, TAPS, and TIMIS, contain legal names and the use of these personnel systems could compromise the identity of a pseudonym holder.  (11-19-2010)
Protecting the Pseudonym Holder's Legal Identity

  1. Any written correspondence including a pseudonym holder's pseudonym and legal name must be protected. E-mail including such information must be encrypted.

Exhibit 10.5.7-1 
Verbatim Text of Section 3706 (RRA 98) from 26 USC 7804, dated July 22, 1998


Pub. L. 105-206, title III, Sec. 3706, July 22, 1998, 112 Stat. 778, provided that:

  1. In General. - Any employee of the Internal Revenue Service may use a pseudonym only if -

    1. adequate justification for the use of a pseudonym is provided by the employee, including protection of personal safety; and

    2. such use is approved by the employee's supervisor before the pseudonym is used.

  2. Effective Date. - Subsection (a) shall apply to requests made after the date of the enactment of this Act [July 22, 1998].

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