11.53.3  Policy & Strategic Planning (Cont. 1)

11.53.3.4 
GAO/TIGTA/IMRS (GTI)

11.53.3.4.4  (11-15-2011)
GTI Structure

  1. The Chief, GTI reports to the Director, PSP.

  2. GTI Lead Analyst reports to the Chief, GTI.

  3. GTI liaisons coordinate, implement, and monitor the audits for the SB/SE Commissioner.

  4. Contact information is available at: http://mysbse.web.irs.gov/CLD/PSP/PSPcontact/default.aspx

11.53.3.4.5  (11-15-2011)
The SB/SE GAO/TIGTA Program

  1. GAO and TIGTA audit SB/SE operations then share audit findings and recommendations with Congress, other federal agencies, and the public.

  2. SB/SE Executives place a high priority on audits since findings can significantly affect the IRS' strategic plan and program initiatives.

  3. The goal of GTI is to bring the necessary stakeholders together.

11.53.3.4.5.1  (11-15-2011)
Roles and Responsibilities

  1. GTI partners with other stakeholders to coordinate the SB/SE GAO/TIGTA audit Program.

  2. The GTI liaison is the primary point of contact for audits. The GTI liaison will notify each SB/SE Business Unit (BU) functional coordinator of an upcoming meeting. Each BU functional coordinator will advise the GTI liaison of the name of the Business Unit's POC for that audit. The POCs who participate in meetings will serve as the secondary points of contact for that audit. The Business Unit POCs and executives participate in meetings and serve as the secondary POCs for the auditors. The GTI liaison coordinates with the SB/SE functional coordinators to:

    1. Ensure all impacted stakeholders are engaged in the audit.

    2. Review the scope and objectives of the audit.

    3. Provide all impacted operating divisions with an opportunity to respond.

    4. Prepare timely responses.

    5. Monitor corrective actions.

    6. Provide periodic status updates.

    7. Facilitate delivery of requested case files in a timely manner.

    8. Facilitate requests for interviews of field or campus personnel.

    9. Direct activities as needed.

    10. Review assigned audit information entered into the SB/SE GAO/TIGTA/Legislative Database and update the audit record weekly as the audit progresses.

  3. After the GTI liaison has provided GAO/TIGTA with the executive and secondary POC information, the auditor can request information from the GTI liaison, the functional coordinator, the executive, the secondary POC, or other personnel within the jurisdiction of the audit. GAO/TIGTA will include the GTI liaison in all information requests submitted in writing, sent via e-mail, or received by telephone.

  4. The functional coordinator, executive, secondary POC or other personnel will forward an e-mail to notify the GTI liaison of all verbal information requests received from GAO/TIGTA. The GTI liaison is responsible for monitoring, tracking, and accurately documenting all audit activity and must maintain ongoing communication with the functional coordinator, executive or secondary POCs and GAO/TIGTA auditors. As appropriate, auditors will contact the GTI liaison for additional assistance in obtaining requested information.

  5. The functional coordinator, secondary POCs and other personnel must observe the following guidelines when sharing information and data or meeting with auditors:

    1. Ensure information requested in engagement letters is available for auditors at the opening conference.

    2. Ensure information and data requested during audits is provided to the auditors in a reasonable and timely manner. In general, a maximum of two weeks is considered timely.

    3. Provide all written comments in response to discussion draft reports are provided to the audit team at least one day in advance of the closing conference.

    4. Ensure management is aware of information and data requested and provided to GAO/TIGTA auditors.

    5. Provide requested information and data directly to the auditors with a copy to management and the GTI liaison.

    6. Use appropriate disclosure and security protocols when forwarding information via e-mail or FAX.

    7. Provide copies of all audit correspondence, data, telephone call notes, meeting invitations, and meeting summaries to the GTI liaison.

  6. GAO/TIGTA liaisons in other BODs have oversight responsibility for the coordination, implementation, and monitoring of the GAO/TIGTA audits that affect their organization. When their audits also affect SB/SE, they will coordinate with GTI for input. GTI clears any input attributed to SB/SE through the Commissioner, SB/SE office. This includes assuming full or partial responsibility for planned corrective actions. The reverse is also true.

  7. After CSO clearance, the Commissioner, SB/SE staff has oversight responsibility for the review and clearance of responses requiring the Commissioner, SB/SE and/or the Deputy Commissioner Services and Enforcement or the IRS Commissioner’s signature.

  8. Legislative Affairs (LA) has oversight responsibility for the coordination, implementation, and monitoring of the GAO/TIGTA audit process for the IRS Commissioner. See IRM 11.5.1, Legislative Affairs - Audit Process For General Accountability Office/TIGTA for detailed information and Exhibit 11.5.1-1 for basic terms used in the audit program.

  9. CFO has oversight responsibility for monitoring GAO/TIGTA audit recommendations and corrective actions.

11.53.3.4.6  (11-15-2011)
Government Accountability Office (GAO) Audits

  1. GAO is the investigative arm of Congress. They examine the use of public funds and federal programs. GAO provides analysis, options, and recommendations to Congress for effective oversight, policy, and funding decisions. The GAO website is located at http://gao.gov/

  2. The GAO audit process includes the following steps:

    • Opening Conference Phase

    • Audit Phase

    • Exit Conference Phase

    • Draft Report Phase (30 Day Response)

    • Final Report Phase (Congressional 60 Day Letter Response)

    • GAO Response Clearance/Approval Process

11.53.3.4.6.1  (11-15-2011)
Audit Process for SB/SE Lead & Non-Lead Audits

  1. For non-lead SB/SE audits, the audit process is generally the same for audits where another BOD is the lead and SB/SE is impacted. The lead BOD is responsible for scheduling openings, closings, progress update meetings, or for preparing final management responses to draft and final reports (GAO reports).

  2. The lead BOD audit liaison is responsible for coordinating, facilitating, and monitoring of the audits that affect their organization.

  3. When impacted SB/SE Business Units provide input or comments for a draft report or 60-day letter, the:

    1. Lead BOD audit liaison provides the response to the GTI liaison for review and approval by SB/SE.

    2. GTI liaison forwards the response to the impacted SB/SE Business Units and then through the Commissioner, SB/SE Executive Assistant.

    3. SB/SE Business Units and the Commissioner, SB/SE indicate approval by initialing the Action Routing Sheet.

    4. GTI liaison then returns the response to the lead BOD audit liaison.

    5. Lead BOD audit liaison reviews the response and forwards through their Executive chain.

      Note:

      If the response changes, the lead BOD audit liaison, forwards the response back to the GTI liaison to review and approve.

11.53.3.4.6.2  (11-15-2011)
Entrance Letter

  1. Generally, the GAO Director of Tax Issues sends a Notification Letter to the National Director, LA, as the designee of the IRS Commissioner, to notify the IRS of a new audit.

    Note:

    Occasionally an audit letter may come from another office within GAO.

  2. The entrance letter, also known as the "Notification Letter," is the official notification that GAO will conduct a formal audit. LA will forward the entrance letter to the Chief, GTI and other impacted stakeholders to initiate the opening of an audit. Audits are assigned to a GTI liaison who serves as the primary POC throughout the audit process.

  3. LA communication includes:

    1. Entrance letter (see example below).

      Date:
      (Name)
      National Director, Legislative Affairs Division
      Internal Revenue Service

      Dear Mr. Xxxxxx,

      At the request of the Chairman of the Senate Committee on Finance, we are beginning work on capital gains tax noncompliance, under job code XXXXXX. Based on the request, our initial objectives are to provide information on
      1. How does IRS address capital gains tax noncompliance for investment income from stocks, bonds, and mutual funds?

      2. What steps, if any, could improve IRS’ ability to address noncompliance for such income and how might they be addressed?


      The Chairman has authorized GAO, pursuant to IRC §6103(f)(4)(A) of the Internal Revenue Code, to have access to all information necessary to perform this work. A copy of the Chairman’s letter is enclosed.

      We plan to contact representatives from IRS’ National Office in Washington D.C., including the Office of Research, Analysis and Statistics, the National Research Program, and from the research and compliance components of the Wage and Investment and Small Business/Self-Employed Divisions at their headquarters.

      We would appreciate your notifying the appropriate offices in your agency and identifying a point of contact for this engagement. We expect to begin our work immediately and would like to hold the entrance conference as soon as possible.

      If you have any questions please contact _______, Assistant Director at (XXX) XXX-XXXX, xxxx@gao.gov or ____ at (XXX) XXX-XXXX, yyy@gao.gov.

      Sincerely yours,

      (Name)
      Director, Tax Issues
      Strategic Issues Team

      Enclosure

  4. If the lead operating unit is not identified or is in question, the GTI liaison attempts to resolve the issue with the assigned LA point of contact. If the issue cannot be resolved, then raise it to the Chief, GTI for resolution with LA.

11.53.3.4.6.3  (11-15-2011)
Opening Conference Phase

  1. Legislative Affairs, not the GTI Liaison, schedules GAO meetings and issues the GAO entrance conference invitation.

  2. The GTI liaison performs the following tasks to implement the audit:

    1. Determines the impacted SB/SE Business Unit(s).

    2. Forwards the invitation to the impacted SB/SE Business Units/stakeholders.

    3. Forwards the entrance letter electronically to all impacted functions, indicating the audit number, title, and reply due date on the subject line of the e-mail. The SB/SE Business Unit functional coordinator ensures their Executive or designee participates at the opening conference.

      Note:

      Use the standard language in the example below when transmitting the entrance letter:

      Subject line: Action: GAO Job Code, Title, Response Due to GTI XX/XX/XXXX
      GAO is initiating a review on (Audit Title and job code). Legislative Affairs schedules the entrance conference. Please let us know by COB (date) which of the following days you are available: Weekday, XX/XX/XXXX, Weekday XX/XX/XXXX, or Weekday XX/XX/XXXX at Time XX:XX A.M. Attached is the entrance letter and cover memorandum for your review. The entrance letter contains an overview of the scope and objectives for the review.

      If you have any questions, please contact me at (XXX)XXX-XXXX.

    4. Enters the audit on the SB/SE GAO/TIGTA/Legislative Database and continuously updates the database throughout the process.

    5. Forwards the meeting invitation to all impacted stakeholders and to SB/SE Research Functional Coordinator.

    6. Provides a list of participants and briefing notes on the meeting if requested.

11.53.3.4.6.4  (11-15-2011)
Audit Phase

  1. The audit phase is GAO’s research and information gathering phase.

  2. The GTI liaison will contact GAO to request the status of the audit. The purpose of the status request is to keep up-to-date with audit activities and to identify significant and/or sensitive issues before issuing the discussion draft report. The GTI liaison will:

    1. Contact GAO each month to request the status of the audit (lead and non-lead).

    2. Request the status of the audit during the second week of each month; the request will have a 3 – 7 day response deadline.

    3. Notify the Chief, GTI when significant and/or sensitive issues are identified. The Chief, GTI will alert the Commissioner, SB/SE Executive Assistant when significant and/or sensitive issues are identified.

  3. The GTI liaison will schedule an interim meeting (if necessary) to discuss the preliminary audit findings. If requested, review audit work papers.

  4. The GTI liaison will:

    1. Update the audit on the SB/SE GAO/TIGTA/Legislative Database. IRM 11.53.3.4.9, SB/SE GAO/TIGTA/Legislative Database.

    2. Maintain the audit records for permanent files.

11.53.3.4.6.5  (11-15-2011)
Exit Conference Phase

  1. GAO conducts an exit conference on all audits and provides a Statement of Facts for comment.

  2. The purpose of the exit conference is to discuss and resolve findings and questions contained in the Statement of Facts document.

  3. GAO provides an estimate of the number of recommendations that may be included in the draft report. Recommendations are not specifically identified until the draft report is issued.

  4. GAO uses this phase to discuss, clarify, or correct data and/or significant issues that may be included in the draft report.

  5. The GTI liaison:

    1. Coordinates with LA to schedule the exit conference.

    2. Notifies the impacted SB/SE stakeholders of the scheduled exit conference.

    3. Forwards the Statement of Facts document to the impacted SB/SE stakeholders.

    4. Coordinates all comments and issues before and after the exit conference.

    5. Updates the audit on the SB/SE GAO/TIGTA/Legislative Database.

11.53.3.4.6.6  (11-15-2011)
Draft Report Phase (30 Day Response)

  1. GAO prepares a draft audit report at the conclusion of an audit, requesting a formal agency response addressing recommendations.

  2. The draft report is assigned a report number that Treasury uses to track corrective actions on the Joint Audit Management Enterprise System (JAMES), discussed in IRM 11.53.3.4.8

  3. The IRS Commissioner generally has 30 calendar days to respond to a draft report. However, the GAO required response due date can be as few as seven calendar days from the date of the draft report if there is a Congressional request for the report. The electronic cover memorandum accompanying the draft report will clearly stipulate the response time required.

  4. SB/SE will provide a response that includes the following:

    • Agreement with finding(s) and recommendation(s).

    • Highlight of successes, achievements, or directives.

    • Corrective actions that address the recommendation(s).

  5. The GTI liaison:

    1. Forwards the draft report electronically to the impacted SB/SE functional coordinators and BOD(s), indicating the audit title, number, and reply due date in the subject line.

    2. Advises the impacted organizations of the pre-established due dates of the response.

    3. Forwards guidance electronically on preparing the response. IRM 11.53.3.4.6.7.

      Note:

      Use the standard language in the example below when transmitting the draft report:

      Subject line: Action: GAO Job Code, Audit Title, Response Due to GTI XX/XX/XXXX
      Attached is GAO’s draft report titled Report Title and Job Code. The response is due to GAO on XX/XX/XXXX. To meet GAO’s due date, your response is due to GTI by XX/XX/XXXX. The following information is attached to assist you with the preparation of the response:
      • Draft Report and Cover Memo

      • GAO Response template

      • Note to Reviewers

      • Action Routing Sheet

      • Sample response

        If you have any questions, please contact me at (XXX) XXX-XXXX.

    4. Schedules and coordinates, if necessary, a draft report meeting. (Recommend meetings when the Business Unit disagrees with documentation in the report, there is disagreement with the ownership of a recommendation, or to ensure agreement with the response).

    5. Identifies program manager responsible for drafting the management response and establishes timeframes for completing the response.

    6. Updates the audit on the SB/SE GAO/TIGTA/Legislative Database.

    7. Notifies the Chief, GTI that a request for an extension from GAO is necessary if a response cannot be drafted within the required time frame. The Chief, GTI contacts LA to request an extension from GAO.

    8. Contacts Legislative Affairs to request an extension on E-TRAK upon approval of an extension request. (Build in half a day for an E-TRAK update.)

11.53.3.4.6.7  (11-15-2011)
Preparation of the GAO Audit Response

  1. The GTI liaison will coordinate and provide guidance on the preparation of the audit response to the lead SB/SE functional coordinator.

  2. The GTI liaison will provide the following information to the functional coordinator to assist with the preparation of the response:

    • GAO response template

    • Action Routing Sheet

    • Draft report and Cover Memo

    • Exit conference or draft report meeting notes, if required

    • Example of an approved SB/SE GAO response

  3. The SB/SE functional coordinator will ensure that the response is prepared with the following in mind:

    1. Use appropriate correspondence format. See IRM 1.10.1, The IRS Correspondence Manual and IRM 1.10.2, Reference Materials for Preparing Correspondence, for guidance.

    2. Write using a positive tone.

    3. Address recommendation(s) in the first few paragraphs.

    4. Address the recommendation(s) and the corrective action(s).

    5. State positive results and/or next steps that address the recommendation(s) (include corrective actions that address the recommendations).

    6. Identify the appropriate program manager and Executive for approval (IRM 11.53.3.4.6.11 for response clearance/approval guidance).

11.53.3.4.6.8  (11-15-2011)
Financial Statement Audit

  1. GAO audits the financial statements of IRS annually with the objective of rendering an opinion, evaluating internal controls, and reporting IRS’s compliance.

  2. At the conclusion of the audit, GAO issues an opinion on the financial statements. The final report is issued annually by November 15.

  3. The Opinion rendered as one of the following:

    1. Unqualified Opinion – In all material aspects, the statements fairly represent financial data and operations.

    2. Qualified Opinion – Except for the circumstances specified in the report, the statements fairly present financial data and operations.

    3. Adverse Opinion – The auditor disagrees with application of certain accounting principles, and statements do not fairly represent financial data.

    4. Disclaimer Opinion – The auditor could not obtain enough evidential matter to express an opinion.

      An unfavorable audit opinion on IRS’ financial statements impairs GAO’s ability to place reliance on the Treasury and Government-wide statements.

  4. In the spring of the following year, GAO issues two related management reports:

    • Improvements Needed in IRS’s Internal Controls (new recommendations)

    • Status of GAO Financial Audit and Related Management Report Recommendations

  5. Timeline of Events:

    1. December – GAO initiates the audit by issuing the engagement letter through Legislative Affairs, who sends it to the Chief Financial Officer (CFO), the lead stakeholder. The CFO controls and forwards the letter to the Business Operating Divisions (BOD). Each of the BODs appoints a liaison who is responsible for coordinating the audit activities. In SB/SE, a GTI liaison coordinates activities and ensures complete coverage and timely responses.

    2. February – March – GAO begins to requests documents via Prepared/Provided by Client (PBC) Listing. BODs are responsible for items identified in their organization.
      GAO may also request a walk-through to understand how work is processed. The CFO circulates Cycle Memoranda, that describe IRS’s operations/processes. There are three memoranda's which SB/SE reviews and updates:
      • Revenue Receipts
      • Refunds
      • Unpaid Assessments
      The Financial Audit liaison coordinates review/update of the memoranda.

    3. February – September – CFO hosts monthly conference calls to discuss PBC Listing updates and other items submitted by GAO or IRS.

    4. March – April – Internal Control Testing at Field Offices. GAO conducts field testing over various aspects of field offices whose responsibilities include receiving taxpayer payments and returns and forwarding them for further processing. GAO issues a letter to the CFO identifying the sites where they plan to conduct field testing one to two weeks prior to the visit. In recent years, GAO has performed this testing in Collection field offices. The GTI liaison works with Operating Unit coordinator to plan visitations and provide CFO and GAO with points of contact for each office. GAO hosts opening and exit conferences at the end of each site visit in which the GTI liaison documents the summary findings.

    5. May – June – GAO issues Matters for Further Consideration (MFCs) which are the findings from the internal control testing at the field offices. IRS agrees or refutes the facts identified in the MFC. We submit proposed resolutions addressing issues in which we concur. If we do not concur with the issue, we are required to support our position on the refuted situation/circumstances.

      During this time, GAO also issues Audit Inquiry Forms (AIFs) which relate to specific issues GAO needs clarification or additional information.

    6. June – September – GAO conducts transaction testing on sample cases for the Unpaid Assessment, Revenue Receipts, and Refund audits at the Kansas City campus.

    7. October – November – CFO issues the After the Audit Report from the transaction testing. The majority of SB/SE findings are from the Unpaid Assessment sample. Responses to the reports are due by December 31.

    8. November 1 – GAO issues a draft opinion on the financial statements (unqualified, qualified, adverse, etc.), including other high-level data, material weaknesses, and reportable conditions. IRS has four hours to coordinate the review by the Executives.

    9. November 15 – GAO issues final opinion on the financial statements and reports the opinion to Treasury.

    10. December – CFO requests the current statuses of open recommendations in the current GAO report, Status of GAO Financial Audit and Related Management Report Recommendations which are due by December 31.

    11. Quarterly – CFO requests updates to open recommendations (March, June, and September).

11.53.3.4.6.9  (11-15-2011)
Establishing Accurate Corrective Action Due Dates

  1. SB/SE’s goal is to establish achievable corrective action due dates. For consistency throughout SB/SE, use the 15th of the month as the due date for all corrective actions. All implementation dates are on the 15th of the month. Delaying actions are rare; however, certain delays, such as those relating to funding, IRM clearance and publication, executive steering committee concurrences, and Work Request (WR) prioritization, are necessary.

  2. To ensure achievable due dates, the GTI liaison will advise the SB/SE Business Units to:

    1. Brainstorm when findings and recommendations are first presented.

    2. Discuss and evaluate each recommendation.

    3. Consider all obstacles when establishing due dates.

    4. Draft a timeline including major milestone dates to arrive at the completion date.

    5. Add additional time to allow for unforeseen obstacles.

    6. Carefully consider the scheduling of due dates when the report includes numerous recommendations where one corrective action must be completed before work can begin on another action.

11.53.3.4.6.10  (11-15-2011)
Final Report Phase (Congressional 60 Day Letter Response)

  1. The final report phase (Congressional 60 day letter response) is somewhat similar to the GAO draft report phase, except the agency must prepare a response for Congressional committee members. See the Legislative Affairs website for the GAO 60 Day Letter List of Chairmen and Ranking Members at: http://irweb.irs.gov/AboutIRS/bu/cl/la/default.aspx

  2. GAO issues the final report that includes the agency's official 30 day response to the draft report.

  3. The final report number remains the same as the draft report.

  4. The GTI liaison provides a copy of the final report to the impacted SB/SE Business Unit(s).

  5. The SB/SE functional coordinator will ensure that the response is prepared with the following in mind:

    1. Be aware of the due date for each corrective action.

    2. Identify the responsible official.

    3. Develop the Corrective Action Monitoring Plan.

      Note:

      Use the following format example to address the Corrective Action Monitoring Plan in the response.

      CORRECTIVE ACTION MONITORING PLAN - We will monitor this action as part of our internal management control process.

    4. Estimate a realistic implementation date to complete the recommendation(s) ( IRM 11.53.3.4.6.9 for guidance).

    5. Identify the responsible official (BOD Executive) for the recommendation(s).

    6. State how the progress of the recommendation(s) is monitored.

    7. Identify the appropriate program manager and Executive for approval (IRM 11.53.3.4.6.11 for response clearance/approval guidance).

  6. Input recommendations and corrective actions in the final report to JAMES. IRM 11.53.3.4.8 for additional information on JAMES.

11.53.3.4.6.11  (11-15-2011)
GAO Response Clearance/Approval Process

  1. The GTI liaison prepares the Action Routing Sheet and forwards it to the lead SB/SE Business Unit to initiate the clearance and approval process for an audit response. The Action Routing Sheet is located at : http://nhq.no.irs.gov/cos/CorrIRM.asp

  2. The GTI liaison includes the following individuals and information on the Action Routing Sheet for review and approval:

    • Responsible SB/SE Director

    • Responsible Program Manager

    • LA GAO/TIGTA Coordinator

    • SB/SE Communications Reviewer

    • Chief, GTI

    • Senior Operations Advisors, CSO

    • Director, CSO

    • Commissioner, SB/SE Executive Assistant

    • Deputy Commissioner, SB/SE

    • Commissioner, SB/SE

    • Director, Legislative Affairs

    • Deputy Commissioner Service and Enforcement (signs 30-day and 60-day responses)

    • File names (short and descriptive) such as Audit number, Shortened Title Draft Report.doc or Audit number, Shortened Title IRS Response.doc

    • The Action Routing Sheet "Subject Line" should contain the title of the audit report and the report number.

    • The Action Routing Sheet Summary Box should contain the following: "Note to Legislative Affairs: Please send the signed, scanned response electronically to (name of GTI liaison). Return the signature package through the Commissioner, SB/SE Office" and "Note to Commissioner, SB/SE Office: Please return the signature package to SE:S:CSO:PSP:GTI, (name and room number of Chief, GTI) via courier."

    • Due Date: Date the response is due to GAO

    • E-TRAK control number

  3. The lead SB/SE Business Unit functional coordinator initiates the clearance process for the response.

  4. The lead SB/SE Business Unit functional coordinator obtains review and approval from the following individuals:

    • SB/SE Program Manager

    • Director and/or Program Manager of other impacted BODs

    • SB/SE Director

  5. The GTI liaison continues the clearance process for the response through:

    • Legislative Affairs (LA)

    • Chief, GTI (review of the response)

    • Senior Operations Advisor, CSO (review & finalize the response with SB/SE Business Unit)

    • Director, CSO (review of the response)

    • Commissioner, SBSE Executive Assistant (review of the response for the Commissioner, SB/SE approval)

    • Deputy Commissioner, SB/SE (signature approval for the Commissioner, SB/SE if required)

    • Deputy Commissioner Service and Enforcement (signature approval)

  6. LA continues the clearance process for the response through Deputy Commissioner to obtain the IRS Commissioner’s approval and signature.

11.53.3.4.7  (11-15-2011)
Treasury Inspector General for Tax Administration (TIGTA)

  1. TIGTA was established in January 1999 in accordance with the IRS Restructuring and Reform Act of 1998 (RRA 98) and provides independent oversight of IRS activities. As mandated by RRA 98, TIGTA assumed most of the responsibilities of the IRS’ former Inspection Service. For additional information, see the TIGTA website at: http://www.treas.gov/tigta

11.53.3.4.7.1  (11-15-2011)
TIGTA Audit Program

  1. The TIGTA audit program is comprised of reviews mandated by statute or regulations, as well as reviews identified through the audit planning and evaluation process.

  2. The TIGTA audit program is presented in the Annual Audit Plan published at the beginning of each fiscal year.

11.53.3.4.7.2  (11-15-2011)
TIGTA Audit Plan

  1. The Annual Audit Plan is based on significant management issues facing IRS, as well as areas of concern from Congress, the IRS Commissioner, and IRS Oversight Board. Emphasis is on the statutory coverage imposed by RRA 98.

11.53.3.4.7.3  (11-15-2011)
TIGTA Workflow Process

  1. TIGTA audits provide independent oversight of IRS activities to promote efficiency and effectiveness in administering the nation’s tax system.

  2. TIGTA's Office of Audit strategically evaluates IRS programs, activities, and functions to ensure that resources expended reduce vulnerabilities in the nation’s tax system.

  3. The TIGTA process includes the following steps:

    • Planning and Research Phase

    • Opening Conference Phase

    • Audit Phase

    • Agreement-to-the-Facts/Closing Conference Phase

    • Closing Conference Phase

    • Discussion Draft Report Phase

    • Draft Report Phase

    • Final Report Phase

11.53.3.4.7.4  (11-15-2011)
TIGTA Planning and Research

  1. TIGTA contacts Legislative Affairs (LA) via e-mail or memorandum indicating the scope of work and the anticipated periods involved for the planning and research project. Engagement letters are not required for these TIGTA audit activities which include audit planning, research activities (surveys, information gathering, etc.), and integrity projects.

    Note:

    Use the following standard language by TIGTA to transmit a planning and research request.

    200940023 - Review of Outreach for Qualified Joint Ventures
    The Treasury Inspector General for Tax Administration (TIGTA) is initiating planning and research efforts on the Internal Revenue Service's (IRS) outreach efforts related to the Qualified Joint Venture tax law provision. We will be conducting our planning work through January 2009. We will send an engagement letter and schedule an entrance conference at the completion of our planning work. This audit addresses the Major Management Challenge of Processing Returns and Implementing Tax Law Changes and is part of our Fiscal Year 2009 Annual Audit Plan.

    The Qualified Joint Venture provision was effective for Tax Year 2007 returns filed in Calendar Year 2008. The provision basically allows a joint husband and wife business to be treated as a sole proprietorship rather than a partnership for tax purposes. The practical effect is the taxpayers will no longer be required to file a Form 1065 (U.S. Return of Partnership Income) and will be allowed to report their income on Schedule C (Profit or Loss from Business) and split the net self-employment earnings on separate Schedules SE (Self Employment Tax). This will reduce taxpayer burden, should decease any cost to prepare the returns, and help ensure the taxpayers are given accurate credit for their Social Security earnings. To qualify for this treatment the taxpayers must make an election each year.
    Proposed Objective:
    Our proposed overall objective is to determine if taxpayers that meet the requirements have been adequately informed of the Qualified Joint Venture provision. To accomplish this we plan to:
    • Contact Taxpayers and Prepares to determine if they are aware of the Qualified Joint Venture provision

    • Review forms and publications to verify the accuracy and effectiveness of the information added related to Qualified Joint Ventures and

    • Identify and evaluate other outreach efforts, if any

      Note:

      Note that these are subject to change based on our planning efforts.

    Office Subject to Review:
    We will be contacting the Media and Publications function which is responsible for updating forms and publications. We will also need assistance from the Wage and Investment CARE (Customer Assistance, Relationships, and Education) office, as well as the National Taxpayer Advocate.

    Please provide us with the appropriate contact points for this planning and research effort.
    TIGTA Contact Points:
    • (Name), Assistant Inspector General for Audit (Returns Processing and Account Services), (XXX) XXX-XXXX

    • (Name), Director (Returns Processing and Account Services), (XXX) XXX-XXXX

    • (Name), Audit Manager, (XXX) XXX-XXXX

    • (Name), Lead Auditor, (XXX) XXX-XXXX

  2. LA forwards the e-mail to the Chief, GTI.

  3. The Chief, GTI assigns the planning and research project to a GTI liaison and informs the LA POC.

  4. The GTI liaison:

    1. Notifies TIGTA that he/she is the liaison and coordinates the planning and research request.

    2. Forwards the e-mail to the responsible SB/SE Business Unit functional coordinator to obtain a POC who will work with TIGTA to address the planning and research request.

    3. Provides the POC to TIGTA. TIGTA will coordinate the audit through the GTI liaison to obtain information unless otherwise directed.

    4. Enters the status of the planning and research project on the SB/SE GAO/TIGTA/Legislative Database.

  5. If the planning and research results in a formal audit, TIGTA will issue an engagement letter through LA. The GTI liaison assigned to the planning and research project will retain the responsibility for overseeing the audit.

  6. If an audit is not warranted, the planning and research project is closed by a TIGTA memorandum.

11.53.3.4.7.5  (11-15-2011)
Engagement Letter

  1. To initiate an audit, TIGTA notifies the IRS through the issuance of an engagement letter from the Deputy Inspector General for Audit to the Commissioner(s) of the BOD(s) that they forward to LA as the designee for the IRS Commissioner.

  2. The engagement letter is the official notification that TIGTA is conducting a formal audit. Once TIGTA issues the engagement letter, the audit is officially open, whether or not an opening conference was held.

  3. The engagement letter contains the following information:

    • Title

    • Audit Number

    • Scope of the review

    • Objective of the review

    • Offices included in the review

    • Information and points of contact required to accomplish audit objectives

    • Deliverables and estimated completion dates

    • TIGTA Executives and other points of contact

      Note:

      Use the following standard language by TIGTA when transmitting an engagement letter.

    MEMORANDUM FOR COMMISSIONER, SMALL BUSINESS/SELF-EMPLOYED DIVISION

    FROM: xxxxxxxxxxxxxxxxx
    Deputy Inspector General for Audit

    SUBJECT: Denials of Written Requests for Information (Audit # XXXXXXXXX)

    The Treasury Inspector General for Tax Administration (TIGTA) is initiating a review to evaluate the Internal Revenue Service’s (IRS) denials of written requests for information. This audit is being conducted because the Restructuring and Reform Act of 1998 requires the TIGTA to conduct periodic audits of a statistically valid sample of the total number of determinations made by the IRS to deny written requests to disclose information to taxpayers on the basis of the Internal Revenue Code (IRC §6103 or the Freedom of Information Act (FOIA) exemption (b)(7). We will be contacting the TIGTA Liaison for the Small Business/Self Employed Division to schedule an entrance conference with the appropriate IRS managers. To allow the posts-of-duty sufficient time to respond to our request for copies of sample cases, we will wait to schedule the entrance conference until (month, year).

    Overall Objective

    The overall objective of our audit is to determine if the IRS improperly withheld information requested by taxpayers in writing, based on FOIA exemption (b)(3), in conjunction with IRC §6103, and/or FOIA exemption (b)(7), or by replying that responsive records were not available.

    Offices Subject to Review

    On-site visitations are within Governmental Liaison & Disclosure. We will also select a sample of denials of written requests for information that all Disclosure Offices closed from (month, day, year) through (month day, year).

    Deliverables and Estimated Completion Dates

    Draft Report issued by (month date, year)
    Final Report issued by (month date, year)

    Information Needed From Auditee

    To accomplish the audit objectives, we require the following information:
    • An extract from the Electronic - Disclosure Information Management System (E DIMS) of all cases closed from (month day, year) to (month day, year). (A separate memorandum will detail our criteria for the extract.)

    • Copies of case files for a sample of cases that will be selected from the above extract



    Designated Treasury Inspector General for Tax Administration Executive Liaison xxxxxxxxxxx, Assistant Inspector General for Audit (Headquarters Operations and Exempt Organizations Programs), xxx xxx-xxxx

    Responsible Inspector General Staff

    Direct questions regarding this review to:
    (Name), Director, (xxx) xxx-xxxx
    (Name), Auditor Manager, (xxx) xxx-xxxx
    (Name), Lead Auditor, (xxx) xxx-xxxx
    (Name), Senior Auditor, (xxx) xxx-xxxx

  4. LA forwards the engagement letter to all of the Operating Division audit contacts including the Chief, GTI with a cover memorandum from the Director, LA Division. The cover memorandum identifies the lead and other operating divisions or Business Units TIGTA expects to contact and an LA POC.

  5. Chief, GTI assigns the audit to a GTI liaison and informs LA.

  6. GTI liaison informs TIGTA via e-mail of the assignment, establishes a relationship, and requests available dates for an opening conference.

11.53.3.4.7.5.1  (11-15-2011)
Lead Process

  1. When SB/SE is assigned as the lead organization, the GTI liaison identifies the appropriate SB/SE functional Business Unit, SB/SE program owner, and other impacted BOD(s) based on the audit objective.

  2. The assigned GTI liaison electronically forwards the engagement letter to all impacted functions and the SB/SE Executive designee regarding the initiation of an audit. Included on the subject line of the e-mail is the audit number, title, and reply due date.

    Note:

    Use the standard language in the example below when transmitting the engagement letter to the SB/SE Lead Director and other impacted BODs to establish a meeting date for the opening conference.

    Subject line: Action: TIGTA Audit Number, Audit Title, Response Due to GTI XX/XX/XXXX

    TIGTA is initiating a review on Audit Number, Title. The Commissioner, Small Business/Self-Employed Division is the lead stakeholder. Attached is the engagement letter and cover memorandum from LA for your review. Please provide the following information to me by COB XX/XX/XXXX:
    • Confirmation that your area is responsible for the above subject audit

    • Name and telephone number of the responsible individual(s) that should attend the opening conference

    • Your availability to participate in the opening conference.



    The proposed dates for the opening conference are as follows:
    1. Weekday, XX/XX/XXXX (Time AM or PM EST)

    2. Weekday, XX/XX/XXXX (Time AM or PM EST)



    Please let me know which date above accommodates your schedule. I will forward an e-mail meeting invitation with the location and conference call information for the opening conference once I receive your reply.

    If you have any questions, please contact me at (XXX) XXX-XXXX.

  3. The GTI liaison enters the audit on the SB/SE GAO/TIGTA/Legislative Database.

11.53.3.4.7.5.2  (11-15-2011)
Non-Lead Process

  1. When another BOD is identified as the lead, the lead BOD liaison coordinates the opening conference.

  2. The GTI liaison:

    1. Identifies the appropriate SB/SE functional Business Unit and program owner impacted by the audit objectives.

    2. Coordinates with the lead BOD liaison, advising him/her of SB/SE participation and obtaining potential opening conference dates.

    3. Forwards electronically the engagement letter and provides proposed dates, when available, for the opening conference to SB/SE Business Unit Executive designee(s). Include the audit number, title, and the reply due date on the subject line of the e-mail.

      Note:

      Use the standard language in the example below when transmitting the engagement letter to the SB/SE Business Unit on non-lead audits to establish a meeting date for the opening conference.

      Subject line: Action: Audit Number, Title, Response due to GTI XX/XX/XXXX

      TIGTA is initiating a review on (Audit Number and Title). The TIGTA review is assigned to the Director, Office of Professional Responsibility, and Commissioner, Small Business/Self-Employed Division. The Director, Office of Professional Responsibility is the lead stakeholder.

      Attached is the engagement letter and cover memorandum for your review. Please provide the following information by COB XX/XX/XXXX:
      • Confirm that you (or your designee) will participate in the opening conference

      • Provide any additional POCs that should attend the opening conference with names and telephone numbers

      • Provide your availability for the dates proposed

      • Weekday, XX/XX/XXXX, (Time AM or PM EST)

      • Weekday, XX/XX/XXXX, (Time Am or PM EST)


      I will forward you an e-mail meeting invitation when I receive the location and conference call information from the lead stakeholder.

      If you have any questions please contact me at (XXX) XXX-XXXX.

    4. Forwards a meeting invitation to POCs upon receipt from the lead BOD liaison.

    5. Enters the audit on the SB/SE GAO/TIGTA/Legislative Database.

  3. The GTI liaison addresses disputes with the lead BOD or functional designation. Unresolved disputes are elevated to the Chief, GTI. When determining lead designations we consider the following factors:

    • Focus of audit

    • Program ownership

    • Impact during review (which BOD is responsible for information/actions)

    • Prior report recommendations

    • Prior response signatures

    • IRM ownership (IRM sections may be owned by other BODS)

    • Form (example, Form 3870, Request for Adjustment) ownership

  4. GTI will advise Legislative Affairs of any change to the lead designation.

11.53.3.4.7.6  (11-15-2011)
Opening Conference Phase

  1. If SB/SE is the lead on an audit, the GTI liaison schedules the opening conference with the SB/SE Business Unit and other impacted BOD(s). It is the shared responsibility of the SB/SE functional coordinator to encourage the Executive from their functional area to participate at the opening conference.

  2. The GTI liaison:

    1. Forwards the engagement letter electronically to all impacted functions. Include the audit number, title, and the reply due date on the subject line of the e-mail.

    2. Forwards a meeting invitation to all impacted stakeholders and encourages SB/SE Executive(s) participation. The Executive has the option to appoint a designee within their function/program area to participate in the conference; invite SB/SE Research to all opening conferences.

    3. Provides a list of participants and briefing notes on the meeting if requested.

    4. Updates the audit on the SB/SE GAO/TIGTA/Legislative Database.

11.53.3.4.7.7  (11-15-2011)
Audit Phase

  1. The TIGTA audit review phase is the same as the GAO audit review phase. IRM 11.53.3.4.6.4

11.53.3.4.7.8  (11-15-2011)
Agreement-to- the-Facts/ Closing Conference Phase

  1. The TIGTA closing conference phase is the same as the GAO exit conference phase except that TIGTA may identify potential recommendations. IRM 11.53.3.4.6.5

  2. TIGTA is required to conduct a mandatory closing conference with the TIGTA audit team and the IRS’ key audit stakeholders when they complete their audit fieldwork. This conference referred to as the Agreement to Findings and Recommendation meeting, the Agreement to the Facts meeting, or the Exit Conference.

  3. TIGTA will request this mandatory closing conference through the GTI liaison.

  4. TIGTA will provide a briefing document of the tentative audit findings and recommendations to the GTI liaison prior to the closing conference.

  5. TIGTA will provide the briefing document at least two full business days before the closing conference to allow for key audit stakeholder review.

  6. The GTI Liaison will review and then distribute the briefing document to the appropriate functional coordinators for their review and distribution to the key audit stakeholders.

  7. The GTI liaison will schedule an internal stakeholder meeting to take place prior to closing conference. Recommend a meeting if the GTI liaison identifies the potential for negative impact, and/or if the key audit stakeholders, after their review of the briefing document, raise concerns.

  8. This internal stakeholder meeting affords SB/SE the opportunity to correct, clarify, or mitigate the document contents prior to the closing conference with the TIGTA audit team.

  9. The GTI liaison will refer to the GAO/TIGTA Audit Notification and Meeting Invitees list on the GTI SharePoint site for required invitees for the closing conference.

11.53.3.4.7.9  (11-15-2011)
Discussion Draft Report Phase

  1. TIGTA issues a discussion draft report after the conclusion of the closing conference.

  2. The discussion draft report identifies findings and recommendations and provides a snapshot of the potential draft report that will require an official response from IRS.

  3. A meeting may be held during the discussion draft report phase.

  4. The purpose of the discussion draft report meeting is to bring all impacted stakeholders together to discuss the audit findings, recommendations, and issues of concern, and to validate the responsible officials.

  5. If requested, review the TIGTA's audit work papers and the reviewed cases/accounts at this time.

  6. A pre-discussion draft meeting based on the report findings and recommendations are at the discretion of the GTI Liaison, SB/SE program owner, and other impacted BODs. The purpose of the pre-discussion draft meeting is to discuss and coordinate the agency’s position on the findings, monetary benefits (outcome measures), and recommendations.

    1. The GTI liaison will schedule an internal stakeholder pre-discussion draft meeting when there are concerns with monetary benefits, clarification or agreement needed concerning the recommendation ownership, program manager responsibility, identification of an author for developing the report response, or the Service’ position.

    2. The Commissioner, SB/SE Executive Assistant will participate in the pre-discussion draft meeting or be briefed in a separate meeting with the impacted director (or designee), functional coordinator, and Chief, GTI or GTI liaison.

11.53.3.4.7.9.1  (11-15-2011)
Discussion Draft Report Activity - SB/SE Lead Audit

  1. TIGTA e-mails the discussion draft report to IRS and Legislative Affairs.

  2. Legislative Affairs distributes the discussion draft report electronically to all impacted BODs.

  3. Chief, GTI forwards the discussion draft report electronically to the GTI liaison, Director, PSP, and Commissioner, SB/SE Executive Assistant.

  4. GTI liaison reviews the discussion draft report and determines if recommendations or monetary benefits (outcome measures) impact any SB/SE Directors.

  5. GTI liaison distributes the discussion draft report electronically within SB/SE to appropriate Business Unit functional coordinators, Director, PSP, Commissioner SB/SE Executive Assistant, and affected BOD liaisons and determines need for discussion draft meeting. The e-mail should include:

    • Outline/bullet recommendations in e-mail message

    • Identify which organization addresses each recommendation

    • State if report includes monetary benefit (outcome measures)

  6. If the functional Business Unit determines that there is no need for a discussion draft meeting because there are no recommendations, issues, or concerns with the discussion draft report, then the Commissioner, SB/SE Executive Assistant will decide if a discussion draft meeting will be held and if a response will be prepared.

  7. GTI liaison e-mails the discussion draft report to the SB/SE Research coordinator, before the proposed date of the discussion draft meeting requesting:

    • Review of sampling methodology

    • Validity of statistical analysis and reporting monetary benefits (outcome measures)

  8. Functional Business Units should prepare in advance of the meeting a written list of their concerns regarding the discussion draft report.

  9. The GTI liaison will contact the TIGTA auditors to determine their availability for a discussion draft meeting. Coordinate the date with the impacted directors and send the meeting invite. The GTI liaison will:

    1. Coordinate with TIGTA to schedule a discussion draft meeting within five work days from receipt of the discussion draft report, if requested.

    2. Ensure the responsible Executive(s), program owner(s), and/or manager(s) participate in the discussion draft report meeting. Request an e-mail from the SB/SE Business Unit's Executive, designee, and/or program manager validating their decline of a discussion draft report meeting.

      Note:

      Use the standard language in the examples below when forwarding the discussion draft report and meeting invitation.

      Subject line: Action: Audit Number, Title, Response Due to GTI XX/XX/XXXX
      Attached is the discussion draft report for Audit Number, Title.

      Please review the report and let me know by COB XX/XX/XXXX if you need a discussion draft report meeting.

      Forward all negative responses from your Executive or program manager to me by e-mail.

      If you have any questions please contact me at (XXX) XXX-XXXX.

      Subject line: Action: Audit Number, Report Title
      Location: Room, Conference Call Number, Access Code

      Attached is the discussion draft report for TIGTA Audit Number and Title.

      The conference call information is:

      Conference call Number: XXX-XXXX
      Access Code: XXXXX
      Contact person: (GTI liaison Name)

    3. Invite SB/SE Division Counsel and Disclosure to the discussion draft report meeting to address recommendations for legislative proposals, regulatory or legal guidance, or disclosure and privacy issues, if needed.

    4. Invite Modernization Information Technology Systems (MITS) and Business System Planning (BSP) to every discussion draft report meeting with recommendations impacting IRM procedures, electronic or paper returns processing or posting, command codes, Master File or systemic adjustments, notice issuance, or re-engineering of business processes.

  10. The GTI liaison will conduct the discussion draft meeting to:

    1. Obtain an agreement to the facts.

    2. Resolve any disputed items, if any.

      Note:

      If the GTI liaison is unable to resolve disputed items, elevate the issues to the Chief, GTI and the Commissioner, SB/SE Executive Assistant.

    3. Clarify any issues regarding the recommendations, if any.

    4. Summarize meeting and requested changes.

    5. Obtain tentative date from TIGTA for issuing draft report.

    6. Determine the author of the response.

  11. GTI Liaison will ensure objectives of the audit findings, monetary benefits (outcome measures), recommendations, and ownership are addressed during the discussion draft report meeting. Internal ownership issues (lead/non-lead) on an audit are discussed off-line between SB/SE and the other BODs. If the GTI liaison cannot resolve the issue, elevate it to the Chief, GTI for a resolution with Legislative Affairs. If at any time during this phase it is believed that information in the report needs redacting because it is Official Use Only (OUO), contact a disclosure specialist.

  12. The GTI liaison will prepare and issue the discussion draft meeting minutes:

    1. The e-mail message will state the SB/SE Director responsible for writing the audit response.

    2. Advise which directors are required to provide input or review/approve the response.

    3. Provide briefing notes on the discussion draft report meeting identifying significant issues agreed upon and addressed.

  13. Immediately following the discussion draft meeting, (encourage response preparation at this point), the GTI liaison will provide the response author and director/functional coordinators with:

    1. Example Action Routing Sheet or actual if known.

    2. Note to Reviewer.

    3. Response memo and attachment template with correct opening and closing paragraphs, and correct wording for "Corrective Action Monitoring Plan" entry.

    4. Response attachment template with correct wording for "Corrective Action Monitoring Plan" entry.

    5. Due date for completing the response.

  14. The GTI liaison will update the audit on the SB/SE GAO/TIGTA/Legislative Database.

    Note:

    The following is a guideline for backward planning in the response writing and clearance process:

    • Commissioner, SB/SE Staff – Minimum three business days

    • Deputy Commissioner/Commissioner – Minimum five business days

    • Director, CSO – Maximum four hours

    • Chief, GTI – Maximum one business day

    • Legislative Affairs – Maximum one business day

    • Impacted directors – Maximum four business days



    The start of the response writing is encouraged during the discussion draft phase with periodic follow-ups to ensure the process has begun.

  15. For guidelines on establishing a due date for a corrective action, see IRM 11.53.3.4.6.9.

11.53.3.4.7.9.2  (11-15-2011)
TIGTA Discussion Draft Response Activity - Non–Lead Audit

  1. TIGTA management issues the discussion draft report to the Department of Treasury and electronically to LA.

  2. LA distributes the discussion draft report electronically to all impacted BODs.

  3. The Chief, GTI forwards the discussion draft electronically to the GTI liaison.

  4. The GTI liaison reviews the discussion draft report and determines if recommendations or monetary benefits impact any SB/SE Directors (outcome measures).

  5. The GTI liaison distributes the discussion draft report electronically to the Director, PSP, Commissioner, SB/SE Executive Assistant, and within SB/SE to appropriate SB/SE functional coordinators. The e-mail will:

    • Outline/bullet recommendations in message

    • Identify impacted organizations

    • State whether report includes monetary benefits (outcome measures)

  6. The GTI liaison will coordinate with impacted directors and/or the lead BOD liaison regarding the discussion draft meeting and invite participants as needed.

11.53.3.4.7.10  (11-15-2011)
Draft Report Phase

  1. GTI will coordinate and provide guidance on the preparation of the audit response to the lead SB/SE functional coordinator immediately after the discussion draft report meeting is held or declined.

  2. The GTI liaison will provide the following information to the SB/SE functional coordinator for preparation of the response:

    • TIGTA response template

    • Action Routing Summary sheet

    • Discussion draft report

    • Discussion draft meeting notes, if required

    • Example of an approved SB/SE TIGTA response

  3. The SB/SE functional coordinator ensures that the response is prepared using the same guidelines identified under the Preparation of the GAO Audit Response. IRM 11.53.3.4.6.7

  4. The SB/SE functional coordinator ensures that the response addresses all monetary benefits (outcome measures).

  5. The GTI liaison updates the audit on the SB/SE GAO/TIGTA/Legislative Database.

  6. For guidelines on establishing a due date for a corrective action, IRM 11.53.3.4.6.9

11.53.3.4.7.10.1  (11-15-2011)
TIGTA Draft Report Activity - Lead Audit

  1. TIGTA management issues the discussion draft report to the Department of Treasury and electronically to LA.

  2. Legislative Affairs assigns E-TRAK Control to the BOD (PSP in SB/SE) and distributes the draft report electronically to all impacted BODs.

  3. The Chief, GTI forwards the draft report electronically to the GTI liaison.

  4. The GTI liaison distributes the draft report electronically to the Director, PSP, Commissioner, SB/SE Executive Assistant, the appropriate SB/SE Business Unit functional coordinators, and impacted BOD liaisons. The e-mail will:

    • Outline/bullet the report recommendations

    • Identify which organization addresses each recommendation

    • State whether report includes monetary benefits (outcome measures)

  5. The GTI liaison will follow-up with directors, functional coordinators, and/or response author until completion and approval by other BODs, all affected non-lead SB/SE Directors, and lead director. The GTI liaison will advise the Chief, GTI of any delays.

  6. Upon receipt of the completed response, the GTI liaison will:

    1. Review and edit for spelling, grammar, active voice, and noun/verb agreement.

    2. Verify titles associated with acronyms.

    3. Ensure proper format requirements.

    4. Consult lead director/functional coordinator if additional content requested or content leaves reviewer with questions.

    5. Negotiate revisions.

    6. Advise the Chief, GTI of delays.

    7. Check that outcome measures are addressed.

  7. The GTI liaison will forward the response electronically to Legislative Affairs for review and editing. Include all clearance documents for review.

  8. After reviewing and accepting appropriate changes made by Legislative Affairs, the GTI liaison forwards all of the response files to the Chief, GTI.

  9. The Chief, GTI will accept minor edits and will forward the response electronically to the Senior Operations Advisor, CSO for review with a cc to the Director, PSP and Technical Advisor. The subject of the e-mail will include "IMMEDIATE REVIEW NEEDED" :

    1. Set the e-mail "Importance" level at High (click Red Exclamation Box).

  10. If content changes requested, the Senior Operations Advisor, CSO to forward the response to the Chief, GTI (with a cc to the Director, PSP). The Chief, GTI will forward the response to the GTI liaison for discussion with the response business unit Director’s staff.

    1. If agreement not reached with the business owner, the GTI liaison will notify the Chief, GTI. The Chief, GTI will forward the response to the Commissioner, SB/SE Executive Assistant for resolution and sign-off/approval. The response package will include the business unit owner’s and the Senior Operations Advisor, CSO version of the response.

    2. The Senior Operations Advisor, CSO will not approve or sign-off for the Director, CSO for versions of the response not approved by them.

  11. The Senior Operations Advisor, CSO will return the response to the Chief, GTI. The Senior Operations Advisor, CSO signs-off for the Director, CSO.

  12. The Chief, GTI will review and accept edits as appropriate and then forward the response to the Management Assistant for formatting and printing.

  13. The Chief, GTI will forward the approved response to the GTI liaison. The Chief, GTI will forward an electronic copy of the approved response to the Commissioner, SB/SE Executive Assistant.

  14. The GTI liaison will complete a paper signature package containing approved response for delivery to Commissioner, SB/SE staff. GTI will ensure that the Deputy Commissioner, SB/SE Staff Assistant logs the file into the correspondence log before pickup by courier.

  15. The Chief, GTI will monitor progress of audit responses with the Commissioner, SB/SE office.

  16. The Chief, GTI and/or GTI liaison will work with SB/SE Commissioner’s office to answer questions, coordinate content changes, and finalize response.

  17. Once the Deputy Commissioner Service and Enforcement (SE) approves the response, forward the response to Commissioner, SB/SE for signature. The Chief, GTI, GTI liaison, and the Commissioner, SB/SE Executive Assistant will work with the Deputy Commissioner SE office to answer questions, coordinate content changes, and finalize response.

  18. Once the Deputy Commissioner SE approves the response, forward the response to the Commissioner, SB/SE for signature. The Commissioner, SB/SE staff will scan and e-mail the signed response to the Chief, GTI and the assigned GTI liaison. Commissioner, SB/SE Staff returns the paper signature package to the assigned GTI liaison.

  19. The GTI liaison will e-mail the scanned response to the appropriate TIGTA Audit Manager, with a copy to BOD/OD functional coordinators who contributed to the response, JAMES Coordinator, and PSP E-TRAK personnel, with instructions to update the E-TRAK control.

  20. PSP E-TRAK personnel will coordinate with Legislative Affairs to close the E-TRAK control.

11.53.3.4.7.10.2  (11-15-2011)
TIGTA Draft Report Activity - Non Lead Audit

  1. TIGTA management issues the discussion draft report to the Department of Treasury and electronically to Legislative Affairs.

  2. The Chief, GTI forwards the draft report electronically to the GTI liaison, Director, PSP, and Commissioner, SBSE Executive Assistant on audits with SB/SE impact.

  3. The Chief, GTI will coordinate with Commissioner, SB/SE Executive Assistant, SB/SE to determine whether a paper signature package is necessary after discussing the SB/SE issues with the GTI liaison.

  4. The GTI liaison distributes the draft report electronically within SB/SE to appropriate SB/SE functional coordinators.

  5. If necessary, the GTI liaison will issue an e-mail message to impacted SB/SE director/functional coordinators, providing:

    1. Example Action Routing Sheet or actual if known.

    2. Note to Reviewer.

    3. Response memo and attachment template with correct opening and closing paragraphs, and correct wording for "Corrective Action Monitoring Plan" entry.

    This message will provide guidance about which SB/SE Directors need to provide response input and approve the response.

  6. The GTI liaison will consolidate and edit response for forwarding to the Commissioner, SB/SE Executive Assistant (Additional Quality Review is completed as part of the lead BOD’s clearance process).

  7. The Chief, GTI will forward to the Commissioner, SBSE Executive Assistant.

  8. The GTI liaison will complete action routing sheet and the response for delivery to the Commissioner, SBSE Executive Assistant.

  9. The Chief, GTI will monitor progress of audit responses with the Commissioner, SB/SE office.

  10. The Chief, GTI and/or GTI liaison will work with Commissioner, SB/SE office to answer questions, coordinate content changes, and finalize response for delivery to Lead BOD.

  11. The lead BOD will consolidate response for clearance. The GTI liaison will ensure that the audit response is cleared and approved at Commissioner, SB/SE level if necessary.

11.53.3.4.7.11  (11-15-2011)
Final Report

  1. TIGTA issues the final report, which includes the agency’s official response to an audit.

  2. The final report is assigned a report number.

  3. The recommendations and corrective actions included in the final report inputted to the Joint Audit Management Enterprise System (JAMES). IRM 11.53.3.4.8

  4. The GTI liaison provides a copy of the final report to the impacted SB/SE Business Unit(s) and updates the SB/SE GAO/TIGTA/Legislative Database.

11.53.3.4.8  (11-15-2011)
GAO/TIGTA Internal Control Program Background

  1. The Department of Treasury tracks the status of its bureaus' corrective actions addressing audit recommendations from the TIGTA and the GAO reports through JAMES. JAMES tracks the progress the bureaus are making in implementing TIGTA and GAO audit recommendations based on Treasury Directive 40-03 that establishes the policies and procedures and assigns responsibilities for implementing and monitoring audit follow-up within the Department.

  2. As the IRS Audit Follow-up Officer, the Chief Financial Officer, specifically the Office of Internal Control (OIC) under the Corporate Planning and Internal Control function (OS:CFO:CPIC:IC), is responsible for evaluating the effectiveness of IRS actions taken in response to audit recommendations from TIGTA and GAO. This office is primarily responsible for the following:

    1. Maintaining and updating the JAMES tracking database.

    2. Informing Treasury and the Financial and Management Controls Executive Steering Committee (FMC ESC) about the status of the audit inventory through periodic reports.

    3. Ensuring the quality and timeliness of implementation of management corrective actions.

  3. The SB/SE Division's JAMES Coordinator is a GTI liaison who coordinates between the OIC and the SB/SE Division for tracking and reporting on TIGTA and GAO audit corrective actions.

11.53.3.4.8.1  (11-15-2011)
Role of the JAMES Coordinator in the Audit Follow-Up Process

  1. The JAMES Coordinator is responsible for coordinating implementation of management corrective actions in response to TIGTA and GAO audit recommendations. The coordinator should:

    1. Forward JAMES verification memoranda and any other OIC memoranda to the appropriate offices (Directors, Senior Operations Advisors, and Functional Coordinators) within SB/SE to request verification of the information provided.

    2. Request status updates from Directors on the open TIGTA and GAO corrective actions.

    3. Review for accuracy and consolidate Corrective Action Status Update forms received from SB/SE Directors.

    4. Brief SB/SE Directors, or their functional coordinators, on problems or issues dealing with updates to TIGTA and GAO corrective actions.

    5. Prepare Business Performance Review (BPR) reports on the status of open TIGTA and GAO corrective actions and provide copies to pertinent SB/SE Directors and Managers.

    6. Assist analysts or functional coordinators with the preparation of concurrence memoranda for changes or closure of planned TIGTA or GAO corrective actions not implemented as planned and forward them to the OIC.

    7. Assist analysts or functional liaisons with the preparation of transfer memoranda to other IRS operating divisions and forward them to the appropriate offices.

    8. Answer questions from the OIC on status updates.

    9. Forward monthly JAMES reports to pertinent offices in SB/SE.

    10. Maintain records on JAMES audit verification memoranda, management updates to corrective actions, and related documents for each of the audit reports and corrective actions (e.g., maintain a corrective actions inventory database).

    11. Act as liaison between SB/SE managers and the OIC on resolution of problems encountered during implementation of actions and during verification of status updates.

    12. Provide guidance to functional coordinators and managers on audit follow-up policy and procedures and brief heads of functional areas about the status of the open inventory, as needed.

  2. Other Duties of SB/SE JAMES Coordinator:

    1. The SB/SE JAMES Coordinator also monitors SB/SE corrective actions in Material Weakness, Reportable Condition, and Remediation plans.
      Material Weakness is a significant program deficiency of sufficient importance to be reported annually to the Department of the Treasury and, ultimately, to the President and the Congress until corrected.
      Reportable Condition is a program deficiency, such as collection of unpaid taxes that requires IRS Executive oversight.
      Remediation Plan is necessary when the IRS’s financial systems do not comply with federal government requirements. Plans include remedies, resources, and target dates for completion. Quarterly reviews are coordinated with the OIC.

    2. The JAMES Coordinator works with the functional coordinators to ensure actions are completed and reported timely.

    3. The Financial Management Controls Executive Steering Committee provides leadership and oversight for GAO and TIGTA audit findings, Material Weaknesses, Reportable Conditions, and the Financial Statements Audit. The committee meets quarterly. When an SB/SE program is on the agenda, the JAMES Coordinator works with the program owners to provide briefing materials prior to the meeting and coordinates completion of any follow-up actions.

11.53.3.4.8.2  (11-15-2011)
GAO/TIGTA Audit Recommendations and Corrective Actions Follow-Up Process

  1. The following sections explain the tracking of the implementation of corrective actions addressing audit recommendations to ensure that the SB/SE Division implements planned actions timely and as stated in the management responses to audit reports.

11.53.3.4.8.3  (11-15-2011)
Audit Verification Using the Joint Audit Management Enterprise System (JAMES)

  1. Once TIGTA or GAO issues a final report, the OIC prepares the JAMES A-6 abstracts and the Audit Verification transmittal memorandum. The abstracts contain a summary of findings, recommendations, and planned management corrective actions, including the amount of any potential monetary benefits. For GAO final reports, initial abstracts prepared after receipt of the final reports show only findings and recommendations because, unlike responses to TIGTA draft audit reports, the management responses to GAO draft reports do not include specific corrective actions, due dates, and responsible officials.

  2. The OIC forwards the JAMES audit verification memorandum transmitting the final report abstracts to the SB/SE JAMES Coordinator requesting verification that the information shown in the abstract is correct, and, if not already provided, the specific corrective actions and original due dates for each audit recommendation (for the GAO report abstracts). The OIC assigns three-digit numbers (e.g., 1-2-3) to corrective actions when developing the final report abstracts in the JAMES tracking system. The first digit represents the finding, the second the recommendation, and the third the particular corrective action number under the recommendation. Exhibit 11.53.3-1, A-6 JAMES Abstract.

  3. The JAMES Coordinator contacts the responsible SB/SE Division Director(s) or functional coordinators to resolve any discrepancies and/or request information on corrective actions. In case of discrepancies in the JAMES abstracts, the GTI liaison prepares a draft response (electronically) to the JAMES verification memorandum for submission by the responsible SB/SE Director(s). If no changes are necessary, the JAMES Coordinator verifies for OIC, and sends an e-mail that the abstracts are correct.

  4. The JAMES Coordinator enters all new corrective actions on the individual function spreadsheets and prepares the monthly e-mails for each SB/SE Director for tracking and reporting purposes.

11.53.3.4.8.4  (11-15-2011)
Corrective Action Status Updates

  1. SB/SE Directors are responsible for implementing the agreed upon corrective actions in the management responses to draft audit reports. The JAMES Coordinator is responsible for monitoring the status of all open SB/SE audit corrective actions and provides SB/SE Directors with Excel spreadsheets containing their function’s corrective action inventory by the 25th day of each month.

  2. Each director through their functional coordinators must provide the current status of all corrective actions due within six months in the "Current Status" column on the spreadsheet. Form 13872, Planned Corrective Action (PCA) Status Update for TIGTA/GAO Reports, is required for each action that is completed or rescheduled. For completed actions, Form 13872 must include specific information about actions taken, completion dates, and any documentation showing implementation of the recommendation. GAO or TIGTA does not consider a recommendation closed simply because the JAMES report says IRS closed it. The auditors may request documentation as evidence of the implemented corrective actions. When preparing status updates, managers should look closely at the JAMES abstracts or the final report to ensure their updates address the recommendations and planned corrective actions in the abstracts. Managers should address any identified monetary benefits in the status update, whether realized or not.

  3. For extensions of due dates, Form 13872 should include specific reasons for delays in implementing actions. When requesting extensions managers should ensure that the delay is attributable to the corrective action. Managers should set revised dates to the 15th of the month following the anticipated completion of the action to allow time to provide a response to the OIC and entry into JAMES. The appropriate director must sign the Form 13872. Managers must list a contact person in the Corrective Action Status Update Form who is a senior manager with subject-matter expertise who can answer questions from the OIC, TIGTA, GAO, or high-level manager.

  4. All updated spreadsheets and approved Forms 13872 are due to the Chief, GTI Branch with a copy to the JAMES Coordinator by the 10th day of the following month.

  5. The OIC will inform the GTI liaison of any pending actions because the status narratives were not satisfactory to either change, close, or delay the actions. Actions involving a Work Request (WR) or revisions to the IRM require full implementation of the programming changes and the actual IRM updates, in order to close them in the JAMES tracking system.

11.53.3.4.8.5  (11-15-2011)
Change/Cancellation of Corrective Actions

  1. To request approval to change planned audit corrective actions or to close audit corrective actions SB/SE could not implement as planned (e.g., programming changes could not be implemented because the WR was not approved or because a planned project was canceled), the Business Unit must prepare a concurrence memorandum for the signature of their director. Include a courtesy copy to the OIC. If the Chief Information Officer function rejects a WR (prepared in response to an audit recommendation), managers must ask Modernization and Information Technology Services (MITS) to provide the denial in writing, including the specific reasons.

  2. Once signed by the Director, the functional coordinator will send the concurrence memorandum to the JAMES Coordinator who is responsible for transmitting the memorandum to TIGTA or GAO. The JAMES Coordinator is also responsible for following up on these memoranda. TIGTA and GAO send their responses to the OIC who then forwards them to the SB/SE JAMES Coordinator.

  3. Managers should request extensions of due dates for corrective actions pending responses from TIGTA or GAO on memoranda requesting approval to close or change their planned corrective actions.

11.53.3.4.8.6  (11-15-2011)
Transfer of Corrective Actions to Another Business Operating Unit

  1. Transfers of corrective actions to another Business Unit require the concurrence memoranda, with attached abstracts of the corrective actions involved, signed by the directors responsible for the audit recommendations and corrective actions, asking for concurrence signature from the appropriate directors in the receiving Business Unit.

  2. The SB/SE JAMES Coordinator forwards copies of the signed memoranda to the OIC and the appropriate JAMES coordinators in the receiving Business Unit (both mailed and faxed hard copies).

11.53.3.4.9  (11-15-2011)
SB/SE GAO/TIGTA/Legislative Database

  1. The SB/SE GAO/TIGTA/Legislative Database is a web-based application designed to help designated users electronically monitor GAO/TIGTA audits.

  2. Database users will maximize the weekly open and closed audit inventory information by obtaining various audit reports, and securing legislative proposal information.

  3. Users will also be able to identify which functions are contributing to the completion of respective audits.

  4. The SB/SE GAO/TIGTA/Legislative Database will allow users and stakeholders to:

    1. Identify and/or track open GAO, TIGTA, and OIG (Office of Inspector General) audits.

    2. Search open and closed audit records.

    3. Obtain historical audit records information.

    4. Access GAO/TIGTA final reports for closed audit records.

    5. Extract reports by business unit functions involved in the audit.

    6. Research and identify issues that have and/or will affect program planning and design.

    7. Identify and track legislative proposals.

11.53.3.4.9.1  (11-15-2011)
Purpose

  1. The purpose of the SB/SE GAO/TIGTA/Legislative Database is to allow designated users to:

    1. Create New Records: The designated GTI lead analyst or GTI management assistant inputs partial audit record information to document a newly assigned audit. The GTI liaison fully updates the audit record thereafter with all necessary audit details as the audit progresses.

    2. Edit Open and Closed records: The designated GTI liaisons are to update/correct existing audit inventory.

    3. Search Open and Closed Records: All designated SB/SE GAO/TIGTA/Legislative Database users have the ability to search open and closed audit records.

    4. Extract Reports: All designated SB/SE GAO/TIGTA/Legislative Database users have the ability to secure and extract all available GTI Reports.

11.53.3.4.9.2  (11-15-2011)
Application Security

  1. All designated SB/SE GAO/TIGTA/Legislative Database users must submit an electronic Form 5081 to gain access to the database.

  2. The SB/SE GAO/TIGTA/Legislative Database Administrator and Chief, GTI will have the authority to add and remove users from the database and to assign permissions.

  3. Executing changes to the data contained in the database is limited to GTI team members, and the SB/SE GAO/TIGTA/Legislative Database Administrator.

  4. The business units must advise the Chief, GTI when a change in personnel requires an addition or deletion of user’s read-only authorization.

11.53.3.4.9.3  (11-15-2011)
Using the Application – Overview

  1. The SB/SE GAO/TIGTA/Legislative Database home page provides a series of menu boxes that allow users to:

    1. Create new audit records and edit existing audit records.

    2. Search the database for open and closed audit records.

    3. Extract standard GTI inventory reports and/or create reports that can be useful to functional business units by selecting specific parameters.

  2. Once users select a menu item, the subsequent pop-up screens include a sequence of drop-down menu boxes that provide users the ease of selecting the necessary parameters for their desired outcome.

  3. Standardized business organization abbreviations along with respective business functions and program names contained in the drop-down menus will provide consistency in selection. This further enhances the search and report extract capabilities of the SB/SE GAO/TIGTA/Legislative Database, Refer to the GTI Inventory User Guide ( http://sbse.web.irs.gov/GAO_TIGTA/GTL_userguide.doc ), Appendix 1, for a complete data dictionary of all terms and abbreviations used in the database.

  4. GTI will closely monitor and update the system to ensure it is meeting the needs of the database customers.

11.53.3.4.9.4  (11-15-2011)
Description of SB/SE GAO/TIGTA/Legislative Database

  1. The SB/SE GAO/TIGTA/Legislative Database currently contains information on the status of all audits accessed through the following menu buttons:

    • Home

    • Create Audit Record

    • Edit Audit Records

    • Search Open Audits

    • Search Closed Audits

    • GTI Reports

    • Submit Legislative Proposal Information

    • Search Legislative Proposal Information

    • Legislative Proposal Reports

    • User’s Guide

    • Admin Only (GAO/TIGTA)

    • Admin Only (Legislative)

  2. Each selected menu button follows a self-directed, streamlined, and structured process that facilitates user searches for information.

  3. This database allows the GTI liaisons to provide a profile on all random, annual, and mandatory audits.

  4. The database also allows users to link directly to GAO/TIGTA final reports on closed audits included as attachments. Users may also conduct direct GAO/TIGTA report searches from the top line menu provided on each screen. Final reports include audit findings, recommendations, and IRS’ corrective actions that may affect current audit responses.

11.53.3.4.9.5  (11-15-2011)
GAO/TIGTA Audit Records Retention & Disposition

  1. Destroy GAO audit files, both electronic and paper, five years after the cut-off period as designated by the National Archives and Record Administration (NARA). The cutoff period for GAO audits is defined as when no further corrective action is necessary. Also refer to IRM 1.15.53(14)(f)(1).

  2. Retire closed TIGTA audit paper files to the NARA Records Center after three years. Destroy records at NARA after the six year designated audit closure research period. Consider an audit closed on the final report issue date. Also refer to IRM 1.15.22(11).

  3. Destroy SB/SE GAO/TIGTA/Legislative Database record and any attached GAO/TIGTA electronic files after the NARA designated six year period.

  4. Following are the procedures for GAO/TIGTA Audits and SB/SE GAO/TIGTA/Legislative Database record retention and disposal:

    1. Identify all files that will be retired to the Washington Federal Records Center (WFRC).

    2. Maintain a log listing the files to be retired as required by NARA procedures.

    3. Complete Form 11671, Certificate of Records Disposal, and submit to the business unit Information Resource Coordinator (IRC). The IRC will review and forward the form to the Area Records Manager (ARM).

    4. Receive notification from the ARM of the approval of Form 11671.

    5. Complete an SF-135, Records of Transmittal and Receipt, after approval notification, and submit it to the area records manager. The area records manager will forward the approved SF-135 to the WFRC for assigning the Accession Number and shipment authority.

    6. Follow the instructions listed on the SF-135 and box the retired files as required by WFRC.

    7. Receive the Accession Numbers by the area records manager and schedule the boxes for pick-up and delivery to WFRC. Note: WFRC is required to store all boxes as received; unopened and taped.

11.53.3.4.10  (11-15-2011)
Issue Management Resolution System (IMRS)

  1. The mission of IMRS is to provide a streamlined and structured process that facilitates stakeholder issue identification, resolution or response, and feedback. IMRS captures, develops, and responds to significant national and local stakeholder issues. The primary purpose of IMRS is to:

    1. Provide stakeholders and practitioners with a method to surface concerns about IRS policies, practices and procedures, and offer suggestions.

    2. Respond to identified issues relating to IRS policies, practices, and procedures in a timely manner.

    3. Share issue resolutions or responses with internal and external stakeholders (nationally and locally) and ask that they share these with other members of their organizations.

    4. Identify trends in filing and paying taxes that may require educational programs, outreach to stakeholders and practitioners, or updates to IRS.gov.

    5. Provide opportunities for exchanges of information between stakeholder and practitioner organizations, and the appropriate representatives.

    6. Refer stakeholder identified issues that require explanation, evaluation, or changes to the responsible IRS function or Business Operating Division (BOD)

    7. Based on IMRS issue identification and analysis, elevate and recommend program and/or procedural changes to the appropriate business owners.

  2. General information on IMRS, including system access and other resources, is available at: http://sbse.web.irs.gov/cl2/sl/IMRS/index_login.asp

11.53.3.4.10.1  (11-15-2011)
Significance of IMRS

  1. Issue management is an important tool in our efforts with stakeholders and practitioners to effectively influence compliance with tax laws. CSO has the primary responsibility to ensure that issues raised by SB/SE stakeholders are addressed and, when possible, resolved.

  2. Issue management through IMRS provides a framework of support for managers to ensure proper tracking and response to stakeholder issues.

  3. Issue management is tracked and monitored through the following databases:

    • IMRS Database

    • IMRS Local Issues Database

    • IMRS Question & Answer (Q&A Database)

  4. The IMRS Database, http://sbse.web.irs.gov/CL2/sl/IMRS/index_login.asp, facilitates tracking and monitoring of national and international issues.

  5. The IMRS Database allows SB/SE a proactive way to gather data on issues, detect trends, monitor and respond to issues, and assist Communications in developing relevant outreach materials.

  6. The IMRS Local Issues Database (LID) captures issues initially raised and worked locally in the Stakeholder Liaison areas.

    1. Local issues are entered into the database and may be worked locally, elevated to IMRS, or referred to other functions such as Tax Forms and Publications. The system design allows each area to easily capture issues and maintain historical data as needed.

    2. Area managers determine who will input issues into the system, either designating specific individuals or giving access to all group members. Along with the area manager, it is the responsibility of the IMRS Working Group (WG) member to monitor the system and provide guidance for resolution of issues.

  7. The IMRS Q&A Database design parallels and expands the IMRS database. The purpose is to catalog and house FAQs for continuing reference and eliminate duplicate research efforts. The system functions as an additional source of information available to IMRS users. The Q&A flow chart available on the IMRS SharePoint site explains the process.

11.53.3.4.10.2  (11-15-2011)
IMRS Roles and Responsibilities

  1. The IMRS headquarters staff includes the IMRS program manager, team lead, and HQ analysts.

  2. The role of the IMRS program manager and team lead is to be both a leader and a facilitator. It involves monitoring, advocating for issue solutions with business owners and program managers, analyzing issues and compliance trends, representing IMRS interests at the national level, and working constructively with other offices and business units while managing relationships in a manner that resolves issues and concerns and fosters taxpayer service and voluntary compliance. The IMRS program manager and team lead work closely with CSO functions including Stakeholder Liaison Field (SL Field), Stakeholder Liaison Headquarters (SL HQ), and Communications, as well as other BODs, such as W&I, to address specific national issues. Some of the specific duties of the IMRS program manager and team lead are to:

    1. Provide oversight of the IMRS program.

    2. Monitor IMRS, together with the IMRS HQ analysts, to ensure timely responses to stakeholder issues.

    3. Facilitate IMRS Working Group efforts to enhance the program, support liaison relations, and identify compliance trends.

    4. Provide input to the Director, PSP Monthly Report, Business Performance Review, Operational Review, and ad hoc reports.

    5. Provide guidance and support to area managers and the IMRS WG members, including the development and delivery of IMRS training.

  3. The role of the IMRS HQ analyst is as follows:

    1. Coordinate elevated issues with the appropriate HQ officials.

    2. Coordinate with CSO Communications in the development of communication products for local and national issues.

    3. Monitor IMRS, together with the IMRS program manager and team lead, to ensure timely responses to stakeholder issues. Confirm SL has promptly shared approved responses with stakeholders.

    4. Identify trends appropriate for key messages and communications to stakeholders through SL outreach activities.

    5. Facilitate the delivery of information/educational materials to internal and external stakeholders.

    6. Identify issue patterns and opportunities to share relevant information with IRS business owners.

    7. Develop a comprehensive strategy for using the IMRS and IMRS Q&A databases to identify and deliver outreach and enhance content on IRS.gov.

    8. Compile reports such as the Monthly Overview, Hot Issues, Industry Issues Quarterly Report, and IMRS Closed Issues Sorted by Subject Report.

  4. The role of the IMRS Working Group (WG) member is as follows:

    1. Promote engagement and involvement in issue response or resolution within their area.

    2. Build and maintain a clear, consistent, communication channel between headquarters and the field on stakeholder issues.

    3. Understand fully and explain to others within their respective areas the uses, capabilities, and procedures for using the IMRS database, the IMRS Q&A database, and the IMRS Local Issues Database.

    4. Serve as a mentor within their area to provide help and guidance with IMRS issues and Q&A identification and development.

    5. Work with the area manager to ensure communication about the IMRS program is continuously shared with their employees.

    6. Review and analyze area issues and Q&As to ensure they are appropriate, properly developed, and worked.

    7. Participate in regularly scheduled Working Group calls. Participate in IMRS Q&A calls and sub-team projects (optional). Participate in informal bi-weekly mentoring calls (optional). Use the IMRS SharePoint site as a group communication tool.

    8. Fulfill the duties and responsibilities of the IMRS WG members as they relate to Communications and communication products.

    9. Ensure that the Stakeholder Liaisons (SLs) in their group are familiar with the IMRS products such as Hot Issues, Industry Issues Quarterly Report, What's New in IMRS?, and the IMRS Monthly Overview.

  5. The role of the SL Field area manager is as follows:

    1. Review issues elevated by employees and determine if appropriate for IMRS. If issues do not meet IMRS criteria, determine appropriate actions needed to address the issues.

    2. Coordinate the use of the IMRS Local Issues Database. See IRM 11.53.3.4.10.8(3), Stakeholder Liaison Activities, for procedures on the IMRS Local Issues Database and ensure that employees take timely action towards resolution of issues entered into database.

    3. Ensure that employees enter appropriate issues into IMRS and elevate issues that are not resolvable at the local level, (i.e., issues with national or international impact).

    4. Discuss issues with SL to determine whether an issue should be elevated to IMRS and approve the issue once input into the system.

    5. Use local relationships to stay informed of developments of interest to IRS functions, practitioners, and industry stakeholders.

    6. Ensure delivery of key messages and/or communication products regarding issue resolutions/responses to internal and external stakeholders.

    7. The Director, SL Field names an SL Field area manager to serve as the liaison between the Working Group members, the SL Field leadership team, and the IMRS HQ staff.

  6. The role of stakeholder liaisons is as follows:

    1. Act as the primary contact point (liaison) for stakeholder, practitioner, and industry organizations.

    2. Maintain regular contact and open lines of communication with stakeholders to ensure early identification of issues and concerns.

    3. Review minutes of the meetings with industry stakeholders and practitioners to identify issues.

    4. Use appropriate research tools to develop and determine the scope of the issue.

    5. Address issues by placing them in the Local Issues Database for identification and local resolution and elevate fully developed issues to the IMRS database, when appropriate, after getting managerial concurrence.

    6. Monitor identified local issues and take appropriate actions to resolve them.

    7. Follow established procedures for responding to or forwarding inquiries to a collector issue. The collector issue process captures these inquiries and forwards them for consideration by the business owner and Communications. (The term Collector Issue is further defined in IRM 11.53.3.4.10.8(1) Glossary of IMRS Terms.)

    8. Follow established outreach request procedures for identifying, updating, or requesting new outreach initiatives or products.

    9. Deliver key messages and/or issue responses to internal and external audiences.

    10. Identify potential issues for IMRS Q&A database and submit to the area's IMRS working group member. (IMRS Q&A explained in IRM 11.53.3.4.10.8(4), Glossary of IMRS Terms.)

    11. Manage expectations of stakeholders as to issue outcomes.

11.53.3.4.10.3  (11-15-2011)
IMRS Outreach Product Request and Guidelines

  1. IMRS provides a comprehensive, multi-functional approach for requesting and/or updating outreach material. The Outreach Request Guidance Document located on the IMRS Intranet home page clearly establishes CSO employee and WG member responsibilities.

  2. The outreach product request approval process is as follows:

    1. SL identifies a need for communication product(s).

    2. SL conducts research to determine whether appropriate products currently exist and, if not, discusses with the WG member.

    3. The WG member uses the IMRS SharePoint site to determine if there is a nationwide need for a communication product by posting a proposed topic for comment. If the response indicates a need for a product or a topic should be added to the Outreach Initiative Database (OID), the SL or WG member opens an IMRS issue and outlines the business reasons for creation of the product in the attached history.

    4. The IMRS HQ analyst assigned to the IMRS issue will contact the communications analyst assigned to IMRS to propose the product or topic.

    5. Note the business owner has the final say in product development and not all requests will be approved. The initiator will receive results of the request.

  3. SL managers and WG members should ensure that employees within their areas understand:

    1. Share only materials approved for external communication with external stakeholders. Materials marked “Internal reference - not for external distribution” are for internal use only and not distributed externally.

    2. Requests for new topics or materials are coordinated through the IMRS and Communications process.

    3. Do not alter News releases and material published on IRS.gov prior to distribution.

    4. “Give stakeholders a hand up, not a handout” has additional guidelines for distribution of written products and handouts. http://mysbse.web.irs.gov/CSO/SL/OutreachMessages/OIDArticles/7900.aspx.

11.53.3.4.10.4  (11-15-2011)
IMRS SharePoint

  1. The IMRS SharePoint site provides a single Intranet workspace for the IMRS HQ staff and IMRS WG to coordinate schedules, organize documents, and participate in discussions.

  2. Authorized users can access documents and information on the IMRS SharePoint site titled "Documents." these sections may include the following:

    • Shared Documents (includes archived Hot Issues, What's New in IMRS?, and Industry Issues Quarterly Reports)

    • Meeting Minutes (prepared from the WG meetings)

    • IMRS HQ Staff Documents (including nationally developed policy documents, flowcharts, guidebooks, and staff listings)

  3. The IMRS SharePoint site also includes the following:

    • Announcements (significant or important messages posted on the IMRS SharePoint Home Page)

    • Links (related Web sites)

  4. WG and HQ staff use the IMRS SharePoint "discussion board" feature to comment about potential issues and requested outreach material. IMRS WG members are strongly encouraged to participate in these shared discussions to provide observations and specific circumstances from their own areas that relate to the items under discussion. Only by including the insights and viewpoints of all area WG members can the IMRS HQ staff make the best possible decisions about how to respond to the issues and concerns raised on the IMRS SharePoint discussion board.

  5. Full access to the IMRS SharePoint site is provided to the IMRS WG members, SL management, and the IMRS HQ staff. Other employees may request read-only access. Direct requests for access to the IMRS HQ staff.

11.53.3.4.10.5  (11-15-2011)
IMRS HQ Staff SharePoint

  1. The IMRS HQ staff SharePoint site provides a shared workspace for the IMRS program manager, IMRS team lead, and the IMRS HQ staff to coordinate proposed policies, post draft documents, share pending issues and concerns, and provide a central location for documents related to specific HQ Staff policies and processes

  2. Authorized users can access documents and information on the IMRS HQ staff SharePoint housed under "Shared Documents" . Other sections include the following:

    • Announcements of specific interest to the HQ Staff

    • Tentative topics for future IMRS WG member conference calls

    • Documents prepared by the IMRS team lead, generally in draft form, for the purpose of gathering input from the HQ staff members. (These may include policy documents, flowcharts, guidebooks, and staff listings.)

11.53.3.4.10.6  (11-15-2011)
Reports and Records

  1. The IMRS HQ staff produces a variety of reports that assist the SL in discussing current issues with their stakeholders and keep them updated on IMRS changes.

    1. The IMRS Monthly Overview provides a brief synopsis of some of the issues received and/or closed during the past month. The current issue is available on the IMRS Intranet home page and current and past issues are available on the IMRS page on IRS.gov. On a monthly basis, the IMRS HQ staff reviews recently opened and closed IMRS issues to determine which ones would provide the best guidance and information for external stakeholders.

    2. The IMRS Hot Issues Report contains IMRS issues and other timely items of interest. The current issue is posted on IRS.gov and the IMRS Intranet home page and updated at least once a month. The report is designed to help a liaison prepare to handle current issues during an outreach event. Archived editions are available on the SL Field and IMRS SharePoint sites.

    3. The Industry Issues Quarterly Report provides a quick synopsis of some of the issues raised through IMRS by or of interest to our industry stakeholders. It is updated quarterly and is designed to help stakeholder liaisons show the value oft IMRS to their industry partners. The current and past three issues are available on the IMRS page on IRS.gov, and the current issue is available on the IMRS Intranet home page. Archived issues are on the SL and IMRS SharePoint sites.

    4. The annual IMRS Closed Issues Sorted by Subject Report contains the significant national and international IMRS issues closed during the calendar year and is available the following year and on the IMRS page on IRS.gov.

    5. "What’s New in IMRS?" is an internal electronic newsletter distributed to liaisons through their IMRS Working Group member. It updates field personnel on changes to IMRS, includes tidbits to help liaisons use the system better, and has articles about recently closed significant issues. Archived issues are maintained on the SL and IMRS SharePoint sites.

    6. The Significant IMRS Issues Report is an internal-use document that includes 12 months of issues whose resolutions resulted in a significant impact for stakeholders. Liaisons should check the document prior to conducting outreach so they will have current examples of important IMRS issues to share with stakeholders when discussing IMRS. This report supplements View 15 on the Outreach Initiatives Database (OID) and updated monthly on the IMRS Intranet home page.

  2. The IMRS HQ staff generates input for the Director, PSP Monthly Report, Business Performance Review, Operational Review, and ad hoc reports.

11.53.3.4.10.7  (11-15-2011)
System Procedures

  1. An IMRS User Guide is available on the IMRS Intranet Home Page.

  2. Access to the System is as follows:

    1. All employees have "research and input" access to IMRS and "research" access to the IMRS Local Issues database. Access is approved at the local level. All employees have "research" access to the IMRS Q&A Database.

    2. Individuals with a need for a higher level of access (approver or administrator) should contact the IMRS team lead.

11.53.3.4.10.8  (11-15-2011)
Glossary of IMRS Terms

  1. Collector Issue - New legislation and regulations often generate numerous questions from practitioners before a business owner or Counsel has finalized and shared the information or procedures necessary to implement them. IMRS may open an issue specifically designed to collect those inquiries.

    • Stakeholder questions are used to help ensure that we address the most common and persistent questions in designing our outreach materials and guidance. We are not able to respond to each practitioner with a separate answer. Establish a collector issue to gather suggestions on topics other than new legislation, such as electronic tax administration.

  2. Issue Management Resolution System (IMRS) - A Web-based application that permits tracking and monitoring of national and international issues identified by Stakeholder Liaison partners and stakeholders. The system provides management officials with a tool to perform a trend analysis to determine how widespread issues are and it also captures issues in a centralized electronic format.

  3. IMRS Local Issues Database – A database developed to capture issues raised in any Stakeholder Liaison area. Issues not resolved locally are elevated to IMRS or referred to other systems.

  4. IMRS Q&A Database – The IMRS Q&A database is designed to catalog and house FAQs so others can use them without reinventing and/or re-researching a response. The system functions as an additional source of information available to the IMRS user. The link to the database is at http://sbse.web.irs.gov/cl2/sl/IMRS_QA/default.asp.

  5. IMRS User Guide – The IMRS User Guide is an on-line guide that describes how to use the IMRS System and provides detailed screen shots of system applications. It is available on the IMRS Intranet home page.

Exhibit 11.53.3-1 
A-6 JAMES Abstract

A-6 - Audit Summary
Bureau: IRS
Report Number(s): 2008-30-091
Start Issue Date:
End Issue Date:
Report Status:
ALL Responsible Official (Report): ALL
Search Text:
Report Type: AR
Bureau Report Number Report Title Issue Date Entry Date Report Status Status Date
Statistics Calculated: 05/29/2008 14:58:43 by GTI LIAISON
IRS 2008-30-091 THE TELEPHONE EXCISE TAX REFUND PROGRAM WAS SUCCESSFULLY IMPLEMENTED FOR BUSINESSES; HOWEVER, A LARGE AMOUNT OF OVERCOLLECTED TAX HAS GONE UNCLAIMED 04/24/2008 05/05/2008 Open 05/05/2008
Report Category Audit Agency Subject Matter Area Conducting Agency Audit Fiscal Year Limited Official Use
  TIG Tax Administration     2008 N
Responsible Official: SE:W/SE:W      
Comments: TCMIS NUMBER: 200730036  
 
 
Finding Num: 1 Status: Open Status Date: 05/05/2008        
Responsible Official: SE:W/SE:W  
Finding Description: EFFORTS TO CREATE COMPLIANCE SCREENS WERE AMBITIOUS BUT INCONSISTENCIES EXIST DESCRIPTION: Compliance screens used tolerances that generally increased in proportion to an increase in the size of the business. However, the minimum tolerances set for some businesses in comparison to others were inconsistent and led to some inconsistent results.    
   
 
Rec. Num: 1 Status: Open Status Date: 05/05/2008 Entry Date: 05/05/2008  
Recommendation: The Director, Electronic Tax Administration and Refundable Credits, should survey tax preparers and business taxpayers who did not claim the Telephone Excise Tax Refund (TETR) to determine why they did not claim the refunds. Such a survey will help the IRS determine whether further actions are necessary to administer the refunds to businesses, assess the effectiveness of its communications strategies, and make appropriate changes for future outreach efforts. Because TIGTA now has limited Office of Management and Budget authority to perform such a survey, TIGTA would be willing to work with the IRS to gather these data. If the results of the survey warrant, the TETR Working Group should identify demographics that had relatively low rates of claims and provide additional information to these business taxpayers on how they might still claim the TETR.  
Responsible Organization          
SE:W              
               
PCA Num: 1 Status: Open Status Date: 05/05/2008 Status Date Entered: 05/05/2008  
Due Date: 09/15/2008 Entry Date: 05/05/2008        
Plan Corrective Action: The IRS agrees that it could learn a great deal from a survey of businesses and tax professionals regarding why they did not request a refund of TETR. The IRS does not have sufficient resources to implement a study of this nature at this time; however, it would greatly appreciate any help TIGTA could provide in conducting such a study. The IRS would be interested in any data regarding why presumably eligible businesses did not claim their TETR refund. The IRS would be able to analyze any data TIGTA could produce to determine trends and common reasons.  
Responsible Organization: SE:W  
Responsible Employee: SE:W:ETARC  
   
 
Finding Num: 2 Status: Open Status Date: 05/05/2008    
Responsible Official: SE:S/SE:S            
Finding Description: EFFORTS TO CREATE COMPLIANCE SCREENS WERE AMBITIOUS BUT INCONSISTENCIES EXIST DESCRIPTION: Compliance screens used tolerances that generally increased in proportion to an increase in the size of the business. However, the minimum tolerances set for some businesses in comparison to others were inconsistent and led to some inconsistent results.    
   
 
Rec. Num: 1 Status: Open Status Date: 05/05/2008 Entry Date: 05/05/2008  
Recommendation: The Director, Campus Compliance Services, and the Director, Examination, should make appropriate changes to the screening criteria for claims on amended returns and should analyze screening criteria before implementing them for future programs to ensure they provide reasonable and consistent coverage.  
Responsible Organization          
SE:S              
               
PCA Num: 1 Status: Open Status Date: 05/05/2008 Status Date Entered: 05/05/2008    
Due Date: 08/15/2008 Entry Date: 05/05/2008      
Plan Corrective Action: The IRS agrees to look at the screening criteria currently used to review and select for audit, amended BMF returns with TETR requests. The IRS is now in the process of reviewing the criteria. However, the IRS would like to point out that it analyzed data from the telecommunications industry and spoke to numerous telecommunications industry organizations and business groups before finalizing the Business Estimation Formula and the TETR selection engine. IRS’ audit selection engine was designed to identify the most egregious questionable TETR refund requests. Because the selection criteria have not changed during the entire 2007 and 2008 filing periods, similarly situated taxpayers have received the same treatment. The IRS believes that the method of selecting egregious TETR requests for examination was both fair and appropriate. However, as noted above, the IRS will reassess these criteria as it relates to amended BMF returns with TETR requests.  
Status/Comment Log            
05/05/2008 SHERRODE OFFICE OF AUDIT COMMENTS: TIGTA does not dispute the fact that similarly situated taxpayers received the same treatment. TIGTA’s issue is the treatment of dissimilar businesses. Allowing a relatively large TETR request for a small business and yet freezing a TETR request for the same or even smaller amount claimed by a much larger business does not seem logical. TIGTA encourages the IRS to address this issue in its reassessment of the screening criteria for amended tax returns.  
Responsible Organization: SE:S  
Responsible Employee: SE:S:E  
               
PCA Num: 2 Status: Open Status Date: 05/05/2008 Status Date Entered: 05/05/2008    
Due Date: 08/15/2008 Entry Date: 05/05/2008        
Plan Corrective Action: The IRS agrees to look at the screening criteria currently used to review and select for audit, amended BMF returns with TETR requests. The IRS is now in the process of reviewing the criteria. However, the IRS would like to point out that it analyzed data from the telecommunications industry and spoke to numerous telecommunications industry organizations and business groups before finalizing the Business Estimation Formula and the TETR selection engine. IRS’ audit selection engine was designed to identify the most egregious questionable TETR refund requests. Because the selection criteria have not changed during the entire 2007 and 2008 filing periods, similarly situated taxpayers have received the same treatment. The IRS believes that the method of selecting egregious TETR requests for examination was both fair and appropriate. However, as noted above, the IRS will reassess these criteria as it relates to amended BMF returns with TETR requests.  
Status/Comment Log        
05/05/2008 SHERRODE OFFICE OF AUDIT COMMENTS: TIGTA does not dispute the fact that similarly situated taxpayers received the same treatment. TIGTA’s issue is the treatment of dissimilar businesses. Allowing a relatively large TETR request for a small business and yet freezing a TETR request for the same or even smaller amount claimed by a much larger business does not seem logical. TIGTA encourages the IRS to address this issue in its reassessment of the screening criteria for amended tax returns.  
Responsible Organization: SE:S  
Responsible Employee: SE:S:CCS  
   
 
Finding Num: 3 Status: Closed Status Date: 05/05/2008        
Responsible Official: SE:W/SE:W  
Finding Description: RESOURCES COULD HAVE BEEN MORE EFFECTIVELY APPLIED TO COLLECT ERRONEOUS TELEPHONE EXCISE TAX REFUND CLAIMS DESCRIPTION: In a prior review of TETR claims made by individuals, TIGTA found that many potentially erroneous claims went unchallenged by the IRS and resulted in excessive refunds. The IRS was unable to scrutinize many of these claims due to limited Examination function resources within the operating division responsible for reviewing those returns. At the same time, other resources set aside to review questionable business claims were under used. Shifting resources from one operating division to another may have enabled the IRS to stop or recover much of the TETR that appears to have gone out erroneously.  
   
 
Rec. Num: 1 Status: Closed Status Date: 05/05/2008 Entry Date: 05/05/2008  
Recommendation: The Deputy Commissioner for Services and Enforcement should give consideration to shifting resources from one operating division to another for future IRS projects or programs if it could help the IRS optimize its effectiveness and achieve its mission  
Responsible Organization            
SE:W              
               
PCA Num: 1 Status: Implemented Status Date: 05/05/2008 Status Date Entered: 05/05/2008  
Due Date: 05/05/2008 Entry Date: 05/05/2008 Close Date: 05/05/2008 Close Date Entered: 05/05/2008  
Plan Corrective Action: The IRS agrees with this recommendation. In fact, it is already part of the way in which the IRS conducts its strategic planning process. The IRS’ goal is to deploy its resources to optimize their effectiveness in enabling the IRS to achieve its mission and objectives. This was certainly the case with its approach to TETR. The IRS considered a number of factors in constructing the TETR examination plan and concluded the allocation of audit resources was appropriate and should not be modified to shift efforts away from other productive work to TETR. Throughout the filing season, the IRS monitored the workload of examiners handling TETR cases and, when deciding how to apportion work, took into consideration a balanced coverage approach and the Business Unit’s overall work plan for the fiscal year. IRS decided to continue examining business returns with multiple issues rather than moving business examination resources to examine single-issue TETR requests from individuals.  
Status/Comment Log          
05/05/2008 SHERRODE Completed per management's response to the draft report dated 3/25/08.  
05/05/2008 SHERRODE OFFICE OF AUDIT COMMENTS: TIGTA recognizes that the IRS decided to continue examining business returns rather than moving business examination resources to examine single-issue TETR requests for individuals. TIGTA disagrees with that decision, particularly since the number of business TETR claims meeting examination selection criteria were well below those planned for, and TIGTA had made the IRS aware of significant non-compliance with regard to individual TETR claims. However, because the IRS has agreed to give consideration to shifting resources from one operating division to another in the future and is even now considering this during its strategic planning process, TIGTA does not disagree with the IRS’ stated corrective action.  
Responsible Organization: SE:W  
Responsible Employee: SE:W  

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