13.2.1 Processing Advocacy Issues


  1. This section provides information about the Office of Systemic Advocacy (OSA) and its functions and responsibilities within the Taxpayer Advocate Service (TAS).

  2. The section details the responsibilities of the Executive Director Systemic Advocacy (EDSA), the Director of Immediate Interventions (DII), the Director of Advocacy Projects (DAP), the Director of Field Systemic Advocacy (DFSA), and the work of their staffs, and their relationships within and outside the Internal Revenue Service (IRS).

  3. This section provides guidance to IRS and TAS employees about how to fulfill their responsibilities in the advocacy process. It also describes the following:

    • The National Taxpayer Advocate's Annual Report to Congress (ARC),

    • The Integrating Advocacy initiative,

    • The Taxpayer Advocate Directive (TAD),

    • The Taxpayer Rights Impact Statement (TRIS), and

    • The processes associated with identifying, submitting, reviewing, assigning, developing, and resolving advocacy issues.


  1. The evolution of TAS began with the establishment of the Problem Resolution Program (PRP) in 1977. PRP was designed to handle taxpayer problems that could not be settled through normal IRS channels. Originally the organization limited its advocacy role, protecting taxpayers' rights only on a case-by-case basis. TAS has broadened the depth and scope of the advocacy mission, placing a new emphasis on protecting taxpayer rights at all levels, within all IRS operating divisions and functions.

  2. During the past several years, both TAS and the IRS have developed a greater awareness of the need to focus on the root causes of problems as well as resolving individual cases. TAS has worked diligently to pinpoint and correct systemic deficiencies that may contribute to problems experienced by all taxpayers.

  3. The 1996 Taxpayer Bill of Rights II (TBOR 2) required the IRS to ensure that designated functional officials respond to the National Taxpayer Advocate's recommendations for improving IRS performance and preventing problems.

  4. The IRS Restructuring and Reform Act of 1998 (RRA 98) brought sweeping changes to TAS. Among the most significant was the development of Office of Systemic Advocacy (OSA) and its elevation to a level equal with Case Advocacy. For additional information, see IRM 13.1.1, Taxpayer Advocate Case Procedures, Legislative History and Organizational Structure.

Goals of Advocacy

  1. The National Taxpayer Advocate (NTA) carries out his or her mission through five major program objectives:

    • Administering the Taxpayer Advocate Program (advocacy through taxpayer cases);

    • Identifying and addressing systemic and procedural problems by analyzing their underlying causes and recommending corrective action (advocacy through analysis and administrative recommendations);

    • Identifying and addressing operational issues that affect taxpayers (advocacy through working immediate interventions) ;

    • Advocating taxpayers’ interests in the submission of legislative recommendations; and

    • Advocating taxpayers' interests through recommending changes to published guidance (Treasury and Counsel published guidance).

  2. Advocacy thus falls into five general categories:

    • Resolving cases of economic burden or systemic burden on individual taxpayers;

    • Addressing immediate interventions to respond expeditiously to operational issues affecting taxpayers;

    • Developing projects that identify and address systemic and procedural problems and recommend solutions;

    • Recommending changes to published guidance to improve administration and reduce taxpayer burden for possible inclusion in the Office of Chief Counsel's published guidance plan; and

    • Proposing legislative recommendations to improve tax administration and reduce taxpayer burden.

  3. TAS is organized around two functions:

    1. Case advocacy; and

    2. Systemic advocacy .

  4. The OSA is not solely responsible for the identification of systemic issues. Employees throughout TAS and the IRS regularly uncover problems that bring additional burden or expense to bear on taxpayers. TAS also draws on observations and suggestions from taxpayers, practitioners, and professional organizations in its effort to improve tax law and administration.

  5. The advocacy role of TAS is apparent in the mission statement: "As an independent organization within the IRS, we help taxpayers solve problems with the IRS and recommend changes that will prevent the problems."


  1. This IRM uses several related terms to describe the advocacy process and procedures:

    1. Advocacy Issue -- The underlying systemic problem or issue that creates disservice, inequity, or otherwise adds to taxpayer burden. Systemic advocacy issues affect significant numbers of taxpayers and are rooted in laws, policies or procedures that are flawed in design or implementation.

    2. Advocacy Issue or Submission -- An idea, suggestion, or reported problem that will advocate for the taxpayer by improving current legislation, taxpayer equity, or service to taxpayers; or by reducing taxpayer burden.

    3. Advocacy Project -- An advocacy issue that has been reviewed, ranked under established criteria, and accepted as a project for assignment and further development.

    4. Advocacy Proposal -- A formal, written memorandum of a recommended change that is presented to an Operating Division (OD) or function empowered to implement the change.

    5. Legislative Proposal -- A formal, written memorandum of a recommended change to an existing law or enactment of a new law that is presented to the National Taxpayer Advocate once a legislative Advocacy Project is completed.

    6. Advocacy Initiative -- The overall advocacy process from identification of the underlying issue through implementation of the accepted Advocacy Proposal.

    7. Published Guidance Proposal --A formal written memorandum of a recommended change to published guidance that is submitted to the Special Counsel to the NTA for possible inclusion in the Office of Chief Counsel's published guidance plan.

    8. Immediate Intervention --An administrative or procedural issue that causes immediate and significant harm to multiple taxpayers demanding an urgent response.

    9. Proactive Advocacy --Assignments such as task force participation, Internal Management Document (IMD) review recommendations, and outreach initiatives designed to detect and avoid potential disservice to taxpayers.

Office of Systemic Advocacy

  1. This section describes the responsibilities, staff and structure of the Office of Systemic Advocacy. It also outlines the connections between systemic advocacy, other organizations within TAS, and IRS programs.

Scope and Responsibilities

  1. The Executive Director Systemic Advocacy (EDSA) is responsible for oversight and direction of the OSA, its two Directors, and their staffs. This position reports directly to the NTA. See the Systemic Advocacy Organizational Chart on the TAS website at: Systemic Advocacy Organizational Chart. For the placement of Systemic Advocacy within TAS, see the Taxpayer Advocate Service Organizational Chart, available at: Taxpayer Advocate Service Organizational Chart.

  2. The advocacy roles and responsibilities of the EDSA and his or her staff include:

    • Immediate interventions ( See IRM

    • Reviewing, for taxpayer rights and burden impact, all internal management documents such as IRMs, Interim Guidance, and Delegation Orders, etc., originating within TAS or external to TAS, that are forwarded to TAS for review.

    • Reviewing, for taxpayer rights and burden impact, all forms, notices, letters, publications or other documents that are referred to TAS for review.

    • Screening and approving issues for development of advocacy projects.

    • Updating the tracking system with current status of projects.

    • Providing acceptance notices, interim updates, and closing feedback to internal and external initiators.

    • Serving as team leader or team member on advocacy projects.

    • Partnering with the ODs and functional units to identify systemic problems, analyze root causes, and monitor and implement solutions.

    • Establishing relationships with associate headquarters offices inside or outside TAS; such as the Employee Suggestion Program.

    • Assisting in the development of Taxpayer Advocate Directives (TADs) and Taxpayer Rights Impact Statements (TRIS’s).

    • Providing guidance for integrating advocacy.

  3. The Annual Report to Congress (ARC) Project Manager is responsible for coordinating the Annual Report. This position reports directly to the EDSA.

  4. The Senior Technical Liaison (Examination) is responsible for Examination related issues and representing the EDSA before the ODs and functions, participating on task forces, teams and outreach efforts to identify systemic issues, processes or procedures affecting taxpayers, and coordinating closely with the business community. The Technical Liaison reports directly to the EDSA.

  5. The Senior Technical Liaison (Collection) is responsible for Collection related issues and representing the EDSA before the ODs and functions, participating on task forces, teams and outreach efforts to identify systemic issues, processes or procedures affecting taxpayers, and coordinating closely with the business community. This position reports directly to the EDSA.

  6. The Senior Technical Liaison (CAS) is responsible for campus related issues and representing the EDSA before the ODs and functions that work within a campus setting. This individual also responsible for participating on task forces, teams, and outreach efforts to identify systemic issues, processes or procedures affecting taxpayers, and coordinating closely with the campus community. This position reports directly to the EDSA.

  7. The Director of Advocacy Projects (DAP) is responsible for working with ODs and functions to find the best solutions to systemic problems and recommend changes to policies and procedures. The DAP manages Technical Analysts and Portfolio Managers. See paragraphs 11 and 12 below for information on these positions. The DAP reports directly to the EDSA.

  8. The Director of Immediate Interventions (DII) is responsible for working with ODs and functions to find the best solutions to administrative or procedural issues demanding urgent responses because they are causing immediate and significant harm to multiple taxpayers. The DII manages Systemic Advocacy Management System (SAMS) Program Managers, the Internal Management Documents (IMD)/Single Point of Contact (SPOC) Program Manager, and Technical Analysts. The DII reports directly to the EDSA.

  9. The Internal Management Documents (IMD)/Single Point of Contact (SPOC) Program Manager is responsible for managing both the IMD and the SPOC programs. The IMD program responsibilities include serving as a liaison to Servicewide Policy, Directives, and Electronic Research (SPDER) and other ODs, coordinating the update and release of the TAS IRM, coordinating TAS reviews of external IRMs ( See IRM, coordinating the creation, revision or review of other TAS IMD products (interim guidance, delegation orders, policy statements, etc.), and serving on the IMD Council and related task forces. SPOC program responsibilities include serving as the single point of contact responsible for clarity of forms, correspondence, and notice redesign and improvement and serving on the Notice Communication Advisory Group (NCAG) and other committees as needed, such as Filing Season Readiness or the Tax Products Coordinating Committee (TPCC) (see paragraph 12, at IRM, below). This position reports to the DII.

  10. The Systemic Advocacy Management System (SAMS) Program Managers are responsible for receiving and evaluating advocacy issue submissions and overseeing SAMS. These positions report to the DII.

  11. The Advocacy Portfolio Managers are responsible for providing support and coordination to the Portfolio Advisors, reviewing and acting as single points of contact for research requests relating to portfolio issues. Portfolio Managers support Area Directors in their role as Portfolio Network Champions; again serving as the single point of contact to facilitate communication and coordination of SA project activities and portfolio development. Portfolio Managers are responsible for coordination and support to the DAP, to facilitate communication and monitoring of advocacy projects assigned to the Director of Field Systemic Advocacy (DFSA). These positions report to the DAP. See IRM

  12. Technical Analysts are responsible for advocacy projects, immediate interventions, serving on task forces with representatives of operating divisions or other functions, and assisting in the preparation of the ARC as assigned. These positions report to both the DAP and DII.


  1. Within TAS, OSA works with Local Taxpayer Advocates (LTAs), Portfolio Advisors, Area Directors, and other TAS employees to identify and solve systemic problems and recommend changes to policies and procedures in order to assist customers and provide the best possible service to taxpayers. Some other partnerships that exist within TAS are:

  2. Director Field Systemic Advocacy is responsible for working with the DAP and DII in systemic advocacy as well as the Executive Director of Case Advocacy (EDCA) to create a union between the case advocacy function and the systemic advocacy function. This union will facilitate the integration of advocacy. See IRM for further explanation. The DFSA reports to the EDCA. The advocacy roles and responsibilities of the DFSA and his or her staff are to provide support and assistance for all advocacy issues. These roles and responsibilities include:

    • Reviewing for taxpayer rights and burden impact, internal management documents such as IRMs, interim guidance, forms, publications, and notices, etc.

    • Serving as team leader or member of advocacy projects, including providing interim updates and closing feedback to initiatives, and possibly serving on a team for the ARC.

    • Updating SAMS with current status of projects, research, charter, action plan, contacts, and time spent.

    • Supporting Portfolio Advisors, Attorney Advisors, and Technical Advisors on projects, including working on the ARC, assisting in the development of TAD’s and TRIS’s.

    • Collaborating with the ODs and functions to identify systemic problems, analyze root causes, and monitor and implement solutions.

    • Providing guidance for integrating advocacy and encouraging the submission of issues by TAS and OD employees.

  3. Field Advocacy Analysts support systemic advocacy in their work. They are assigned to work approved advocacy projects controlled on SAMS and related items such as IRM reviews, advocacy portfolio assistance, task forces, studies, and other duties as prescribed by their manager. They will not receive individual case advocacy cases. These positions report to a Field Systemic Manager under the DFSA.

  4. Within IRS, the OSA works through its relationships with the ODs and functions to identify, develop, and recommend solutions to problems while providing quality customer service to taxpayers. Under the National Service Level Agreements (SLAs), the ODs and functions will work with the EDSA to identify opportunities for systemic improvement.

  5. The Taxpayer Advocacy Panels (TAPs) are composed of citizen volunteers nationwide who are appointed by the Secretary of the Treasury. They provide taxpayers with a public forum to voice concerns or recommend improvements to IRS customer service.

  6. The Taxpayer Advocacy Panel (TAP) Managers support advocacy through these roles and responsibilities:

    • Receiving advocacy issues from the TAP organization; and

    • Providing initial and interim feedback to panel members.

  7. The Taxpayer Advocate Panel (TAP) Program Manager has the following advocacy roles and responsibilities:

    • Screening and approving advocacy submissions for elevation to the EDSA;

    • Logging advocacy submissions; and

    • Briefing the NTA on panel issues.

  8. Low Income Taxpayer Clinics (LITCs) are independent organizations that provide low income taxpayers with representation in federal tax controversies with the IRS for free or for a nominal charge. The clinics also provide taxpayer education and outreach for taxpayers who speak English as a second language.

  9. External Stakeholders such as taxpayers, practitioners, academic/research institutions, business and professional groups are solicited by the OSA to provide advocacy issue submissions and feedback and to work with the OSA as part of the overall effort to protect taxpayer rights and reduce taxpayer burden.

  10. The TAS Communications and Liaison Group (CLG) is a vital link between TAS program areas and the field. This task-driven group is a working advisory board for all communication strategies, activities, products, and policies involving the TAS organization. The CLG serves as an extension of the Headquarters Communications & Liaison staff and provides a field perspective on communication initiatives.

  11. The Tax Products Coordinating Committee (TPCC) operates through the Tax Forms and Publications office in Wage and Investment and ensures that all IRS organizations have a voice in creating and improving forms and instructions. The IMD/SPOC Program Manager, or other employee designated by management, represents TAS on the committee, keeps Systemic Advocacy employees informed about proposed revisions to forms and publications, and solicits TAS feedback about these revisions.

  12. The Local Taxpayer Advocates (LTAs) have various advocacy roles and responsibilities, which are essential to the success of the advocacy process. The roles of the LTA include:

    • Maintaining advocacy portfolios as assigned by the NTA;

    • Identifying and submitting advocacy issues;

    • Assisting in resolving immediate interventions and recommending remedies; and

    • Assisting in researching and preparing TADs.

  13. TAS Attorney Advisors report directly to the NTA. They provide assistance and support for Advocacy Portfolios, Advocacy issues, the ARC, and the TAS IMD Review Process. They are expected to be available to external submitters as well as internal employees.

  14. The Special Counsel to the National Taxpayer Advocate (CNTA) provides legal advice and support to the NTA and the Office of the Taxpayer Advocate. Within the Office of Chief Counsel, CNTA has primary jurisdiction over the following issues:

    • IRC § 7803(c), including the LTA's discretion not to disclose information to the IRS under IRC § 7803(c)(4)(A)(iv);

    • IRC § 7811;

    • TADs;

    • The scope of TAS's statutory authority or delegated authority to the extent not previously addressed in written legal advice; and

    • Issues regarding TAS legislative proposals or any other matter related to the NTA's reports to Congress.

  15. The TAS Area Directors (ADs) support the advocacy process. Their advocacy roles and responsibilities include:

    • Identifying and submitting advocacy issues.

    • Encouraging staff to submit advocacy issues.

    • Assisting in resolving immediate interventions and recommending solutions.

    • Elevating unresolved issues to the DNTA and the NTA; and

    • Providing oversight guidance and support in the role of Portfolio Network Champions.

  16. The role of the Headquarters/Program Director in the portfolio process is generally one of support, guidance, issue coordination, and oversight. These directors support the implementation of the NTA's concept of Integrating Advocacy, and make assignments to PAs with Program Support portfolios.

Integrating Advocacy

  1. The OSA is vital to the successful implementation and oversight of the Integrating Advocacy concept within TAS. This approach will maximize the technical expertise of the LTAs by including them in the identification and resolution of systemic issues at the earliest point.

  2. Effective coordination with field components of TAS is key to developing successful advocacy initiatives. The realignment of staff from systemic advocacy to support the work of LTAs and ADs creates an environment wherein front-line Field Systemic Advocacy Analysts work with Case Advocates, IRS personnel, LITC workgroups, and TAP issue committees on real-time identification and resolution of systemic problems.

Integrating Advocacy: Goals and Responsibilities

  1. The integration of systemic and case advocacy in the field will promote the following goals:

    • Enhanced role for LTAs : By assigning issues of national importance to LTAs, TAS is able to leverage the experience, expertise, and field contacts of these invaluable resources. Each LTA Portfolio Advisor (PA) is assigned a customized advocacy portfolio on which he or she will represent TAS, provide a field perspective, and serve as an advisor. LTAs will also be available to represent TAS on selected task forces and issue committees, and to participate in the formulation of the ARC.

    • Early identification of systemic issues : Many systemic issues surface in field locations (including campuses). Integrating advocacy will facilitate both awareness of such problems and the rapid responses needed to correct them. Case advocates, analysts, technical advisors, managers and LTAs are expected to identify and raise systemic problems as well as suggest approaches for resolution through SAMS for consideration and coordination.

  2. The NTA is the only person who determines if an issue will become an advocacy portfolio and makes portfolio assignments. The portfolios will generally be given to LTAs but can be assigned to others, as the NTA deems appropriate.

  3. Requests for changes should be made through the ADs, who will coordinate with the DNTA before proposing a portfolio change to the NTA.

  4. An Advocacy Portfolio assignment is part of the role of the LTA. An LTA who receives a case that aligns with his or her portfolio but does not meet established criteria to be transferred should follow the guidance in IRM 13.1.17, TAS Case Transfer Process .

  5. The OSA staff will work with TAS attorney advisors, LTAs (Portfolio Advisors), and managers to address problems in the tax system. Issues identified through the SAMS database or the Taxpayer Advocate Management Information System (TAMIS) database (See IRM 13.4.1, General TAMIS Information) and matters of interest to the NTA will form the basis of the systemic advocacy workload.

Policy vs. Procedure Decisions

  1. Policy refers to the strategic approach and direction TAS takes on servicewide issues and procedures. The NTA formulates TAS policy with input from TAS staff. When PAs represent TAS in meetings, task forces, or discussions with ODs, it is imperative that they distinguish policy from procedural issues and understand that the views they represent are those of the TAS organization.

  2. Procedure refers to the steps of a process as outlined in a procedural memo, IRM, or LEM. These procedures are designed to reflect the steps that result in the most efficient path to the highest quality product. Decisions that change approved procedures should be reviewed to verify that the change does not increase taxpayer burden or infringe on taxpayer rights.

Keeping the National Taxpayer Advocate Informed
  1. When attending meetings or serving on teams and task forces related to a portfolio, it is critical to keep TAS and the NTA informed of any significant developments, including discussion of changes in policy. As a TAS representative, the PA will advocate the TAS position but will not address policy issues. PAs should provide immediate updates directly to the NTA with copies to the AD, the EDSA, the DAP, the assigned PM, and the Director of Technical Analysis and Guidance (TAG), while at the same time adding periodic updates to the SAMS database.

Advocacy Role of the Portfolio Managers (PM)
  1. See IRM, paragraph 11, under Scope and Responsibilities, for a definition of the role of Portfolio Managers (PMs). PMs are the central point of contact and coordination among the Portfolio Advisors (PAs), DAP, FSA, and Portfolio AD Network Champions in support of integrating advocacy activities and projects. The OSA has designated PMs to support LTAs with tax administration portfolios in their PA roles. PMs provide consistency in the portfolio process and other requests. However, LTAs assigned non-tax administration portfolios (e.g., the TAS CLG, mentoring, etc) by the NTA will be supported by the appropriate headquarters/program director for the TAS program.

  2. See Exhibit 13.2.1-1, Interim Advocacy Portfolio Guidance, for additional guidelines regarding the Portfolio Program.

Advocacy role of the Portfolio Advisor (PA)
  1. A PA is expected to represent TAS, provide a field perspective, and if called upon, provide advice and input on his or her portfolio issue(s). Some PAs will also contribute to the NTA's ARC and the fiscal year objectives report. Each PA must stay abreast of events and developments within his or her assigned portfolio and must input actions, contacts, and research for portfolios on SAMS. This includes:

    • Monitoring operating division procedures, alerts, etc;

    • Monitoring the TAS workload to identify trends and issues;

    • Reviewing the NTA's annual reports and congressional testimony;

    • Attending internal and external meetings as requested and approved;

    • Participating in task forces and conference calls as requested and approved; and

    • Participating in various outreach activities as requested and approved.

  2. The PA is to be an emissary rather than a decision maker. In all types of communications, PAs must be clear as to whether what they say is the official opinion of the NTA, TAS, or alternatively, their own view based on experience with the issue. PAs must clearly state that they are not making a commitment on behalf of the NTA unless authorized to do so by the NTA.

  3. To fully understand the issue(s) and represent TAS, it is critical that PAs are able to ask questions and maintain positive working relationships to obtain substantive information.

  4. The PAs will be expected to advise and support the NTA and other TAS staff. They may also be asked to provide feedback concerning changes to IRMs, forms, publications, notices, etc., as they relate to the various portfolios. PAs will need to establish communication with their peers in the appropriate business units in order to stay informed of upcoming policy and procedural changes that coincide with portfolios. Communications with operating division staff should only take place at the peer level. The DAP will be responsible for making proper contacts with executives and following the appropriate protocols. A PA should consult his or her PM before making contacts outside TAS.

  5. OSA will:

    • Arrange for Portfolio Advisors to make informal contacts with ODs (exceptions are requests related to the Most Serious Problems);

    • Ensure the "Portfolio Network" groups are self-evaluative, and

    • Ensure the AD’s are involved in improvement opportunities.

Virtual Teams within Systemic Advocacy
  1. Virtual Technical Teams arise within SA to work issues on SAMS. The teams are composed of Systemic Advocacy employees and can also include a Portfolio Advisor, Revenue Officer Technical Advisor (ROTA), Revenue Agent Technical Advisor (RATA), or Campus Technical Advisor (CTA) with expertise in a technical or procedural issue for which the SAMS program managers may need additional information. The responsibilities of the Virtual Technical Team include:

    • Reviewing issues in real time, helping the SAMS PMs evaluate issue submissions by clarifying or confirming certain technical processes and procedures described in the submissions;

    • Adding details to selection and prioritization criteria analysis;

    • Reviewing issues for technical soundness; and

    • Enabling workflow capabilities to eliminate delays.

Advocacy Initiatives

  1. These initiatives identify the process from identification of the issue through the proposal. This subsection identifies the goals of advocacy initiatives and the types of advocacy remedies.

Goals of Advocacy Initiative

  1. The goals of an advocacy initiative are to improve taxpayer service, improve taxpayer equity (or fairness), and reduce taxpayer compliance burden. The proper means of accomplishing these goals will vary, depending on the nature of the underlying problem.

  2. Immediate interventions require quick action, even if such action only eases the problem temporarily until a permanent solution is found. Certain issues require a combination of expeditious actions.

Types of Advocacy Remedies

  1. Advocacy remedies typically fall into the following main categories:

    1. Immediate interventions

    2. Administrative changes

    3. Published guidance

    4. Legislative changes

    5. Proactive advocacy assignments

    6. Advocacy proposals

Immediate Interventions
  1. An immediate intervention is an operational issue, identified internally or externally, which causes immediate, significant harm to multiple taxpayers and demands an urgent response. An immediate intervention issue cannot be resolved soon enough through the normal corrective process.

  2. Immediate Intervention issues have clear sources; are highly visible and sensitive locally, area wide or nationally; and require that a resolution be identified within three (3) to five (5) calendar days of the actual start date.

  3. Examples of immediate intervention issues could include the mailing of erroneous information to hundreds of thousands of taxpayers, possibly resulting in penalties for late or incomplete filing of returns; or a campus sending incomplete instructions to more than 3,000 practitioners and creating a potential financial hardship for a large group of taxpayers if the incorrect guidance is followed.

  4. An immediate intervention issue project may result in an Advocacy Proposal, a TAD, an IRM Procedural Update (IPU), (formerly known as Taxpayer Service Electronic Bulletin Board, or TEBB notice), or another type of procedural change.

Administrative Changes
  1. Administrative change projects identify and address systemic and procedural issues, analyze underlying causes of problems, and recommend corrective actions. Advocacy projects of this type are appropriate when the solutions to the issues raised require further research, process analysis, collection and interpretation of data, or coordination with ODs and functions, and when the IRS can administratively implement any necessary changes by amending current policies or procedures.

Published Guidance Proposals
  1. Published guidance proposals may be warranted when an existing Treasury Regulation, Revenue Ruling, Revenue Procedure, Notice or Announcement needs to be amended or new guidance published to improve equity or fairness and reduce burden for taxpayers.


    A News Release is not considered "published guidance."

Legislative Proposals
  1. Legislative proposals may be warranted when an existing law must be modified or a new one enacted to improve equity or fairness in the tax code, improve service to taxpayers, or reduce taxpayer burden.

  2. All TAS legislative proposals are submitted to the NTA for potential inclusion in the Annual Report to Congress. The NTA decides which proposals should be included.

Proactive Advocacy Assignments
  1. The preceding advocacy initiatives are reactive in nature, arising from the need to correct problem situations. Advocacy assignments can also be proactive.

  2. Proactive advocacy assignments are outreach initiatives designed to detect and avoid potential harm to taxpayers. Proactive or preventive steps require an advocacy presence in matters such as program, policy, and project planning; filing season readiness; and the review of forms, publications, notices, etc. from the taxpayer's point of view. An example of proactive advocacy is found in the IMD and SPOC reviews of draft IRMs, interim guidance, forms, etc., during the clearance process. These reviews enable SA to address issues before they become systemic problems or taxpayer burdens.

Advocacy Proposals
  1. An advocacy proposal is used when TAS wants process owners to consider a project proposal or suggestion to change procedures, policies, or activities. The Advocacy Analyst will draft this memorandum, attaching the proposal, an executive summary and a closing letter. The process owner is asked to respond in writing with its decision.

  2. An advocacy proposal can be used as a precursor to a proposed TAD if the advocacy proposal fails to resolve the issue

  1. Advocacy remedies may also include other items such as IMD reviews, Proposed Taxpayer Advocate Directives or actual TADs, and possible submissions to the Annual Report to Congress.

Reviewing Internal Management Documents (IMDs) For Systemic Issues

  1. This subsection covers the procedures for reviewing IMDs, generated both within and outside TAS, for systemic issues. Other TAS IMD processes, such as procedures for Interim Guidance regarding E-FOIA, are detailed in IRM 1.11.13, TAS Internal Management Document (IMD) Program.

  2. IMD products consist of documents providing policy, authority, and procedures, such as Policy Statements, Delegation Orders, Interim Guidance Memoranda, SERP Interim Policy Updates (IPUs), and IRMs and LEMs and Service Level Agreements (SLAs) and Memoranda of Understanding (MOUs). See IRM 1.11.1, Internal Management Documents.

  3. The TAS IMD review process is extremely important and due care should be taken to ensure changes in IRS policy, authority, and procedures do not cause adverse impact on taxpayers. See Exhibit 13.2.1-2, Flow Chart for Reviewing Internal Management Documents (IMDs).

Receipt of IMD Review

  1. All IMD product reviews will come into TAS to the IMD/SPOC Program Manager in Systemic Advocacy for control and distribution of the review request throughout TAS, as appropriate, based upon subject matter expertise and portfolio listings. In addition, the IMD/SPOC Program Manager will provide the CNTA an opportunity to review all chapters of IRM 13 and other IRMs primarily owned by TAS.

Comprehensive Review
  1. If the abbreviated review indicates that the IMD product should have a comprehensive review, the IMD/SPOC Program Manager, or designee, will either enter the review on IMD SPOC SharePoint site at http://co.ds.irsnet.gov/sites/CL/TAs/SA/IMD/default.aspx or on the SAMS "Notes" tab, attaching the file. SAMS or the IMD Staff will email the appropriate reviewers or their managers within 4 business days from the "actual start date." SAMS, the SharePoint site, and/or a separate email are used by the appropriate Technical Liaison, the Attorney Advisor Group Manager, and designated staff members from the Field Systemic Advocacy(FSA) and Internal Technical Advisory Program (ITAP), and any other appropriate reviewers. The IMD/SPOC Program Manager will also provide a response date for forwarding the completed review. The reviewers should enter their comments on the IMD Review Template ( See Exhibit 13.2.1-3.) and attach the document to SAMS using the cut and paste feature. The completed IMD Review Template should be forwarded to the *TAS IMD SPOC mailbox by the response date.

  2. All reviewers should receive email notification of the assignment. The review will be made available to the reviewers through one of two delivery methods:

    • Emailing from the *TAS IMD SPOC mailbox; or

    • Posting to SAMS.

    This must be done within four business days of the initial receipt of the review. These individuals will pull the files for their reviews from the SAMS site upon receipt of the SAMS notification that occurs when projects are staffed with team members on SAMS. For those reviewers who are not SAMS users, notification emails should be sent to them by the IMD Management Assistant.

  3. The response date for the TAS reviewers to complete their reviews will typically be two weeks, unless it is an expedited or rush review. The timeframe (normally 30 days) is based upon the due date indicated on the originator's Form 2061, Document Clearance Record, reduced by the front-end time needed to load the review and the back-end time (typically 7-10 days) to allow the IMD/SPOC Program Manager, or designee, time to compile, edit, and elevate the review for management consideration, as necessary. If a review cannot be completed timely, the reviewer's manager should notify the IMD/SPOC Program Manager so that an extended response date can be requested of the originating office.

  4. If a reviewer does not agree with the language in a document, rather than just indicating non-agreement, they should provide suggested language for how best to revise the document. See below.

Completing the IMD Review and Posting Time
  1. Once the review is completed, the Case Advocacy business units (FSA and ITAP) and other SAMS users working the review will each post their completed review documents as follows:

    • Post the review comments on SAMS under the "Notes" tab for the appropriate folder, using the copy and paste function.

    • Attach under the "Files" tab in SAMS or forward by email to the *TAS IMD SPOC mailbox, the completed Word file prepared from the IMD Review Template discussed above.

    • Send notification of review completion to the IMD Staff via the SAMS "Notification" tab


    Reviewers who are not yet SAMS users (all reviewers should submit Form 5081 and obtain SAMS access) will notify the IMD/SPOC Program Manager by email, using the *TAS IMD SPOC mailbox, that their review is complete and attach the review document to the email notification.

  2. Time performing IMD reviews should be charged on SETR to "Proactive Advocacy/Assignments - OFP 36762" on Form 3081. Reviewers should remember to use their assigned SETR Function Code when entering time (i.e., Analysts use Function Code 900; Technical Advisors use Function Code 740).


    The LTAs will continue to report time under the SETR code for Portfolios: OFP 36765.

  3. Time spent conducting IMD reviews must also be entered on SAMS.

  4. Any issues that cause the reviewer concerns should be raised to his or her manager and to the TAS IMD/SPOC Program Manager.

  5. The IMD/SPOC Program Manager will provide the completed review comments to the OD and negotiate the recommended changes. When the negotiations are unsuccessful and the issue is significant, the IMD/SPOC Program Manager will elevate the issue. Elevation of a review where the OD negotiation has been unsuccessful will be accomplished by the IMD/SPOC Program Manager notifying the DII and the appropriate Technical Liaison of the issue for their review and comment. If they concur that it should be elevated, the DII will notify the EDSA. The EDSA will then review earlier comments and consult with the appropriate Attorney Advisor, prior to elevation to the NTA. However, efforts should be made to resolve the issue, as appropriate, at each step along the way.

Taxpayer Advocate Directives

  1. Delegation Order 13-3 (IRM, empowers the NTA to issue Taxpayer Advocate Directives. TADs mandate that functional areas make certain administrative or procedural changes to improve a process or grant relief to groups of taxpayers (or all taxpayers). This authority is discussed at IRM 13.1.4, TAS Authorities.

  2. TADs work in much the same way that Taxpayer Assistance Orders (TAOs) grant relief. But while a TAO requires only the approval of an LTA, the authority to issue a TAD is delegated solely to the NTA and may not be re-delegated .

  3. TADs are limited to situations in which the NTA has previously requested a change to improve a functional process or grant relief to taxpayers. TADs do not interpret law. They will only be used when the NTA believes specific actions are necessary to:

    • Protect the rights of taxpayers;

    • Ensure equitable treatment; or

    • Provide an essential service to taxpayers

  4. The NTA will summarize TAD activity, including Proposed TADs or Advocacy Memoranda, in the National Taxpayer Advocate's Fiscal Year Objectives Report to Congress.

The TAD Process

  1. Before considering a TAD, the NTA first attempts to work with the process owner(s) to implement change. To facilitate negotiations, advocacy proposals for procedural or policy changes will be communicated to the affected operating area(s) via:

    1. Informal Communication;

    2. Advocacy Proposals;

    3. Proposed TADs; and

    4. TADs.

Informal Communication
  1. The EDSA and staff should always partner with process owners to resolve advocacy issues. If informal discussions and negotiations break down, the LTA and DFSA Advocacy Analyst should discuss the next step with management who may then work with the process owner to reach agreement.

  2. Depending on the nature of the issue, the EDSA or the NTA may or may not decide to pursue informal communication with the pertinent IRS function. If informal communication does not resolve the issue, the Systemic Advocacy representative will draft an Advocacy Proposal for submission by the EDSA .

Proposed TAD
  1. A proposed TAD may be used when process owners do not respond to an advocacy proposal or do not agree to implement a recommendation. In most cases, this serves as a step prior to a formal TAD from the NTA.

  2. A proposed TAD may transmit a proposal and recommendations directly to the process owner.

  3. A proposed TAD is sent to the Area Director, Territory Manager or Head of Office of the responsible operating area(s), generally at the Headquarters functional level.

    1. If a policy or procedure is unique to a specific territory, region, or campus, the proposed TAD may be addressed to the head of that office (with a copy to the headquarters Functional Chief).

    2. A copy of the proposed TAD will be sent to the Deputy Commissioner for Services and Enforcement.

  4. A Taxpayer Rights Impact Statement (TRIS) is a written analysis from the NTA to the particular OD or function relating to the IRS activity or procedure that infringes on taxpayers’ rights or unnecessarily burdens taxpayers.

  5. Proposed TADs and TRIS's are generally not sent until after the function is given an opportunity to work with the NTA to resolve the issue.

  6. The proposed TAD will specify a time period to respond. The NTA may grant an extension.

    1. The response can take the form of an agreed action to resolve the problem, a counterproposal, or an explanation of why the proposed action or change cannot or should not take place.

    2. The NTA may accept an alternative suggestion or proposal by the function to jointly work toward a solution.

Issuing TADs
  1. The NTA may issue a TAD if the process owner does not respond to a proposed TAD within the specified time period, or if the NTA receives what he or she considers an unsatisfactory response.

    1. The TAD will explain why the function’s response is not satisfactory.

    2. A copy of the TAD will be provided to the operating division or function and the Deputy Commissioner for Services and Enforcement.

  2. In instances where the NTA determines that the problem is immediate in nature and will have a significant negative impact on taxpayers, he or she may issue a TAD immediately, without the intervening step of a proposed TAD.

    1. This will be done only if the NTA and the Deputy Commissioner determine that allowing normal timeframes would keep the action from being implemented.

    2. The Deputy Commissioner will immediately review such "expedited" TADs.

    3. The parties involved (the NTA, the Deputy Commissioner, and the chief of any impacted operating division or function) will meet as soon as possible to resolve the issue.

TAD Appeal Process

  1. The only avenue of appeal, should a functional area disagree with the TAD, is to the Deputy Commissioner for Services and Enforcement. See IRM, Delegation Order 13-3 (formerly DO-250, Rev. 1) (01-17-2001), Authority to Issue Taxpayer Advocate Directives.

    1. The chief of the area(s) subject to the TAD may appeal the proposed action within ten (10) calendar days of the date on the TAD.

    2. An appeal must include analysis of why the proposed action cannot or should not be implemented.

    3. The NTA or Deputy Commissioner may extend the ten-day period if he or she determines more time is needed to provide information or analysis that was not included in the response to the TAD.

Role of Systemic Advocacy in the TAD Process

  1. The Systemic Advocacy organization is responsible for assisting with reviewing and finalizing Advocacy Memoranda, Proposed TADs and TADs, in addition to TRIS's. The following steps will be taken if a memorandum is to be issued:

    1. The team under the direction of the Attorney Advisor will draft the memorandum, with required attachments.

    2. The Technical Analyst will ensure that the technical content is correct and the issue properly documented.

    3. The designated analyst consults with the Special Counsel to the NTA about the content of the memorandum.

    4. The Special Counsel to the NTA reviews all proposed TADs and TADs.

    5. The Technical Analyst will submit the memorandum to SA management for approval and signature.

    6. The EDSA will brief the NTA on any advocacy memorandum before submitting it to the process owners.

    7. The OSA management will determine and elevate any issue that requires NTA signature to the NTA for issuance.

National Taxpayer Advocate's Annual Reports to Congress

  1. IRC § 7803(c)(2)(B) requires the NTA to submit two reports each year to the Committee on Ways and Means of the House of Representatives and the Committee on Finance of the Senate. These reports are the National Taxpayer Advocate's Fiscal Year Objectives Report to Congress and the National Taxpayer Advocate's Annual Report to Congress (ARC). Both documents must go directly to the committees without prior comment or review from the IRS Commissioner, the Secretary of the Treasury, the Oversight Board, any other Treasury officer or employee, or the Office of Management and Budget (OMB).

Objectives Report

  1. The National Taxpayer Advocate’s Fiscal Year Objectives Report, due every June 30, outlines for Congress the plans and goals of the Office of the Taxpayer Advocate for the coming fiscal year. This report compiles objectives from different segments of TAS. It should draw input from case advocacy, systemic advocacy initiatives, and "special projects" (TAP, cross-functional teams and task forces, etc.).

Preparing the Annual Report to Congress

  1. The NTA and the Systemic Advocacy staff have developed a working format for the ARC. While addressing all requirements of IRC § 7803(c)(2)(B)(ii), the report is broken down into four major categories;

    • The Most Serious Problems (MSPs) Encountered by Taxpayers;

    • The National Taxpayer Advocate's Legislative Recommendations (LRs);

    • The Most Litigated Issues (MLIs); and

    • Case Advocacy and Systemic Advocacy.

  2. The NTA's Attorney Advisors and the Office of Systemic Advocacy are responsible for preparing the ARC. The EDSA must give the NTA an independent, impartial assessment of the merits of existing proposals and procedures. TAS employees must fairly and accurately measure the impact of existing or proposed practices on taxpayers and the tax system. They must work toward the goal of correcting practices and provisions that impose burden on taxpayers or raise questions about complexity, fundamental fairness and equitable treatment.

  3. Consulting the NTA on the content and format for the ARC is a critical step in preparing each year's report and developing the action plan. Project work will be an integral part of this report. The OSA will also gather data and help prepare the report.

The Most Serious Problems (MSPs) Encountered by Taxpayers
  1. IRC § 7803(c)(2)(B)(ii)(III) requires the NTA to address in the ARC at least 20 of the most serious problems (MSPs) taxpayers faced in the last fiscal year. The NTA and OSA identify, analyze and propose corrective action for specific issues, though these topics may fit into broader areas of discussion such as tax law complexity.

  2. Discussion of each of the MSPs encountered by taxpayers should include:

    • Definition of problem;

    • Identification of responsible IRS official (i.e., an OD commissioner);

    • Analysis of problem;

    • IRS comments;

    • IRS initiatives to resolve problem (if any); and

    • The NTA’s response to the IRS’s reply and any administrative recommendations that the NTA may have to resolve the problem.

  3. The IRS comments and responses to the MSPs are coordinated through the Office of the IRS Commissioner. The operating divisions and functions should be given a minimum of 30 days to respond to each problem identified by the NTA.

The National Taxpayer Advocate's Legislative Recommendations (LRs)
  1. This section of the ARC provides details of legislative proposals submitted by the NTA. The NTA recommends changes in the IRC directly to Congress when current IRC requirements create inequitable treatment, or when a change may ease taxpayer burden or improve taxpayer service.

  2. The NTA’s Legislative Recommendations(LRs) propose specific changes to tax laws. Each recommendation should include a summary page, identifying a specific problem and containing at least one example, followed by a detailed discussion of present law and reasons for proposing the change, including analysis of the proposal’s impact on taxpayers and IRS administrative burden. Any example must comply with IRC § 6103.

  3. TAS may receive legislative recommendations, information and data from internal and external stakeholders. Internal sources include IRS Operating Divisions, Functional Units and the IRS Office of Chief Counsel. The external stakeholders include tax professional associations, the Taxpayer Advocacy Panel, LITCs, and other tax practitioners.

  4. The ARC is the end result of advocacy initiatives undertaken all year, as TAS employees identify, develop and work issues. Many of these problems require administrative solutions. Where no administrative resolution is feasible, the employee should begin to develop the case for a legislative proposal, weighing it against the need to ease taxpayer burden, achieve simplification, maintain or enhance tax administration, efficiency, and equity, and minimize revenue impact. The ARC is the only vehicle for the transmission of TAS legislative proposals to Congress. See also IRM, Legislative Proposals.

The Most Litigated Issues (MLIs)
  1. IRC § 7803(c)(2)(B)(ii)(X) requires the NTA to describe the ten issues most frequently litigated by taxpayers. Analyzing the most litigated issues may reveal areas of tax law that create or increase burden for taxpayers or should be simplified.

  2. The list of MLIs is derived from a variety of sources. Federal tax cases are tried in the United States Tax Court, the United States District Courts, the United States Court of Federal Claims, the United States bankruptcy courts, the United States Courts of Appeals, and the United States Supreme Court. Attorney Advisors and OSA analysts work with the Office of Chief Counsel to track and research cases and the issues involved, uncover patterns related to these issues and determine why they reached the courts instead of being settled administratively.

Case and Systemic Advocacy
  1. This section of the ARC reviews TAS case advocacy for the preceding fiscal year, detailing receipts, closures, Taxpayer Assistance Orders (TAOs), and congressional cases. It also describes the systemic problems causing the greatest concern to taxpayers and TAS's efforts to resolve them, often by working cooperatively with the ODs and functions.

Annual Report to Congress Archive and Briefing Book
  1. Analysts working on the ARC will also prepare an archive of material to be kept in the Systemic Advocacy office, and a briefing book for the NTA.

  2. The archive should include copies of items that each analyst or team relied on in analyzing issues and developing recommendations, or that support, clarify, and provide additional details about the data and conclusions in each section of the report. It is not necessary or desirable to include every communication or source of material used in preparing the ARC, especially sections of the IRC or IRM, or materials used solely for background information.

  3. Archive materials should be shipped to the OSA in Washington after the NTA delivers the ARC to Congress. Each shipment should include an archive transmittal listing the items in the order in which they are filed.

  4. The Briefing Book pieces for each MSP and LR should consist of:

    1. 4-6 pages in total length;

    2. Summary Section that explains the issue(s) in one paragraph and recommendations in a second paragraph (much like the Executive Summaries except that the NTA is the intended audience so we can provide more detail).

    3. Fact Section consisting of highly concentrated data in bullet point form with footnotes. The data should include key statistics and facts used in the MSP or LR as well as relevant statistics and facts that were not used but could conceivably figure into the NTA’s explanation of the topic or answers to questions. Organize the bullet points under different points that the data was used to support so that the NTA can see how we used the data. Go through your research material again carefully to extract relevant facts and data that made it into the MSP or LR.

    4. Question and Answer Section - This section attempts to anticipate the questions the NTA is likely to receive about the piece. Please provide both the questions and answers.


    The briefing book must be completed and delivered to the NTA on or before the date the ARC is delivered.

  5. Systemic Advocacy managers or NTA Attorney Advisors may give more detailed instructions about preparing the archive and briefing book.

  6. The electronic versions of the Annual Report and the Objectives Report, which are available on both the IRS public website and the employee intranet, must comply with Section 508 of the Rehabilitation Act as amended in 1998. Under Section 508 (29 U.S.C. 794d), agencies must give disabled employees and members of the public access to information that is comparable to the access available to others.

Interim Advocacy Portfolio Guidance


The purpose of this memorandum is to establish interim guidance for Local Taxpayer Advocates (LTAs) in their roles as Portfolio Advisors to the National Taxpayer Advocate, as well as guidance for Network Champions, Portfolio Managers and others participating in the portfolio process. This guidance supersedes the Portfolio Guide until completion of a new guide.

The purpose of this guidance is not to impose new portfolio obligations on Portfolio Advisors; rather, the intent with these guidelines is to provide clarifications as to:
• Who is available to assist you in the development of your portfolio;
• What actions can Portfolio Advisors take to develop their portfolios;
• Where should portfolio development be documented;
• Why are portfolios so important to the National Taxpayer Advocate; and
• How the portfolio process works.


The purpose of an advocacy portfolio is for Portfolio Advisors to become subject matter experts in their topics so they will be able to assist the National Taxpayer Advocate in satisfying her numerous statutory duties, including:
A. Assisting taxpayers in resolving problems with the Internal Revenue Service, IRC § 7803(c)(2)(A)(i);
B. Identifying areas in which taxpayers have problems in dealings with the Internal Revenue Service, IRC § 7803(c)(2)(A)(ii);
C. Proposing changes in the administrative practices of the Internal Revenue Service to mitigate problems, IRC § 7803(c)(2)(A)(iii);
D. Identifying potential legislative changes which may be appropriate to mitigate problems, IRC § 7803(c)(2)(A)(iv); and
E. Reporting to Congress as required by IRC § 7803(c)(2)(B)(i)-(ii).


A. Portfolio Advisors: Portfolio Advisors are Local Taxpayer Advocates assigned an advocacy portfolio. It is the responsibility of the Portfolio Advisor to:
(1) Substantively Understand the Topic: Understand the important legal, procedural and policy aspects of the portfolio topic and understand the IRS’s obligations for the topic in tax administration.
(2) Use Knowledge in Advocacy for Taxpayers: With the assistance of participants in the portfolio process, utilize knowledge gained about the portfolio topic to assist in:
(i) Identifying trends in taxpayer services or enforcement;
(ii) Correcting problems in the IRS’s application of the law, policy or procedure;
(iii) Revising IRS procedures that cause undue burden on taxpayers or which fails to follow the dictates or intent of the law or regulations, and
(iv) Consulting with Systemic Advocacy analysts and Field Systemic Advocacy analysts as the analysts develop action plans, functional contacts and solutions or recommendations on project issues relating to portfolios.
(3) Attend and Participate in Network Meetings: Attend and actively take part in your Network Champion’s quarterly meetings. These meetings are an important forum for you to ask questions, raise concerns, share your experiences and learn from the experience of others.
(4) Initiate Sub-Network Group Calls: Portfolio Advisors may want to initiate calls outside of the quarterly meeting process to discuss issues with the Network Champion, Portfolio Manager, or any combination of the individuals who work together to support the portfolio process.
(5) Report on Progress of Portfolio Development: Report at least quarterly on activities in your portfolios.

B. Network Champions: Network Champions serve as the portfolio coach, guiding the portfolio towards full development utilizing a range of activities and relationships to accomplish the task. Network Champions will lead quarterly meetings to:
1) Guide the Portfolio Advisors in understanding the substantive aspects of the portfolio;
(2) Offer ideas for developing the portfolio;
(3) Assist the Portfolio Advisor in determining whether they need technical assistance, from Attorney Advisors, TAS Researchers, or analysts from other TAS functions, such as Technical Analysis and Guidance (TAG) and Field Systemic Advocacy (FSA), and Internal Technical Advisor Program (ITAP).
(4) Assist the Portfolio Advisor in determining whether to contact IRS operating division to develop the portfolio and provide assistance in obtaining those contacts.

C. Portfolio Managers: Portfolio Managers provide the link between the Portfolio Advisor and Systemic Advocacy. Portfolio Managers will assist Portfolio Advisors by:
(1) Providing information on portfolio issues that relate to TAS initiatives on the topic, including information on:
(i) Annual Report to Congress projects;
(ii) Immediate interventions and advocacy projects; and
(iii) TAS-IRS joint task forces.
(2) Link Portfolio Advisors to TAS and IRS operating division initiatives related to their topic.

D. Attorney Advisors: Attorney Advisors provide legal guidance on issues surrounding portfolio topics.

E. Area Directors: Area Directors provide the essential managerial feedback and support that are essential to portfolio development, including:
(1) At least bi-annually, Area Directors will provide feedback about whether expectations and commitments with respect to portfolios are being satisfied.
(2) Portfolio Advisors should raise the following issues on portfolios through their Area Directors:
(i) Termination of existing portfolio in exchange for new portfolio topic;
(ii) Obtaining new portfolio topic as well as current portfolio topic; and
(iii) Other issues regarding the portfolio process that Area Directors may request from time to time.

F. Other Participants: Other participants in the portfolio process can play important roles in developing portfolios. The Network Champions, Portfolio Managers and Portfolio Advisors will coordinate the contacts of these other participants in the portfolio process, including:
(1) Technical Analysis and Guidance (TAG) Analysts: For portfolio topics that relate to issues affecting taxpayers who seek TAS assistance, TAG analysts can provide information and analysis.
(2) Field Systemic Advocacy (FSA) Analysts: FSA analysts can provide analysis on issues submitted on the Systemic Advocacy Management System (SAMS) that relate to portfolio topics.
(3) Internal Technical Advisor Program (ITAP) Analysts: ITAP analysts can provide technical guidance on portfolio topics.
(4) TAS Research Personnel: TAS Research staff can assist Portfolio Advisors by obtaining data relating to portfolio topics.
(5) Collection and Examination Liaisons: Systemic Advocacy’s Collection and Examination Liaisons can provide information about collection and examination issues being worked in Systemic Advocacy and may be able to provide contacts with the IRS Collection and Examination functions.
(6) Internal Management Document Review (IMD) Coordinator: The TAS IMD Coordinator is responsible for coordinating review of proposed IRM changes of the IRS’s operating divisions. She also serves as the Single Point of Contact (SPOC) for IRS notice review. The IMD Coordinator can assist in portfolio development by referring to the Portfolio Advisor IRM and notice revisions relating to the portfolio topic.


A. Working with your Network Champions, Area Directors and Portfolio Managers
(1) Discuss Topic with Network Champion and Portfolio Manager: At the quarterly Network calls and in individual discussions, Portfolio Advisors should discuss portfolio development with the Network Champions and Portfolio Manager. The Network Champion is the portfolio coach and can help identify ways to develop the portfolio. Champions leverage their knowledge gained at the Director Level and can share information relevant to the portfolios. Through sharing portfolio activity in the quarterly meetings, Champions are able to recognize the involvement of each Portfolio Advisor with respect to their issue. Champions can then tailor contact as needed with those Portfolio Advisors who may need individual attention because of varying levels of portfolio development. Portfolio Managers can provide the perspective of Systemic Advocacy on the issue, as well as organizational history on the issue, such as Annual Report to Congress, advocacy projects, immediate interventions and task forces.
(2) Sub-Network Calls: Portfolio Advisors can initiate calls outside of the network calls with their Network Champions to accomplish tasks too detailed to discuss on Network Champion calls. These calls can include some or all of the following: Network Champion, Portfolio Managers, Attorney Advisors, FSA analysts, ITAP analysts, TAG analysts or other TAS personnel involved to assist LTAs with their portfolios.
(3) Discuss with Area Director: Portfolio Advisors should discuss their portfolio action plan and other expectations on portfolio development with their managing Area Director. These discussions may be included in the commitment setting and midyear conferences. Managing Area Directors are encouraged the consult with the LTA’s Network Champion when setting portfolio commitments and to share with the Champion the final commitments.
(4) Portfolio Feedback by Network Champions to Managing Area Directors: Network Champions will provide periodic feedback to the Portfolio Advisor’s managing Area Director on the status of the portfolio Issue Development and Activity Plan. This feedback should address progress towards meeting the agreed upon action plan and the initiative shown in developing the portfolio.

B. Portfolio Set-up and Development: All Portfolio Advisors should create an action plan for the development of their portfolio. A sample action plan is provided in Attachment A. The plan should consider at least all the steps described below, as well as additional steps that would assist in development of the portfolio. Over time, the action plan will need to be updated, i.e., old items deleted, new items added. While each portfolio is different, the actions below are steps to assist in the development of portfolios.
(1) Internal Revenue Code, Treasury Regulations and Other Sources: If your topic derives from the Internal Revenue Code, become familiar with the statute, relevant Treasury Regulations and other IRS published guidance.
(2) Internal Revenue Manual (IRM): Identify and become familiar with pertinent sections of the IRM to the extent your topic is addressed in the IRM.
(3) Other IRS Publication: If your topic is addressed in other IRS documentation such as IRS Forms or Publications or the Taxpayer Assistance Blueprint, become familiar with them.
(4) National Taxpayer Advocate’s Perspective: Research whether the National Taxpayer Advocate has addressed your topic in her Annual Reports to Congress, the Objectives Report, or in her congressional testimony or other public statements.
(5) Identify Trends: To the extent the portfolio topic relates to taxpayers with cases in TAS; attempt to identify trends in TAMIS cases. (6) Conduct an Environmental Scan: Research your topic from all sources, including the Internet, IRS intranet, law review articles, congressional testimony and other sources.
(7) Ongoing TAS Initiatives: Determine whether there are ongoing projects related to your topic in Systemic Advocacy, TAG, ITAP, TAS Research or other TAS functions. If so, contact representatives from those groups to obtain more information and explore opportunities for participation.
(8) Ongoing IRS Initiatives: Determine whether there are ongoing initiatives related to your topic in the IRS operating divisions. The Network Champion and Portfolio Manager can assist Portfolio Advisors in making these determinations.
(9) IRS Contacts: Find and establish IRS contacts that work on issues on the portfolio topic. The Network Champion, Area Director and Portfolio Manager can help Portfolio Advisors establish this contact.

C. Continuous Improvement Cycle: The development and progress of each portfolio will be different from every other due to numerous variables, including: the timing of IRS initiatives, the extent to which the portfolio topic is evident in TAS casework, and the numbers of taxpayers affected by the topic. The extent of experience of an LTA may also impact a portfolio’s development. The goal and purpose of the Network Champions process is to create an environment in which the portfolios can continuously improve and move along the path towards development through feedback and assistance from all participants in the process. This continuous improvement cycle process is illustrated in Attachment B.


SAMS is the current vehicle through which Portfolio Advisors document their portfolio development. This documentation should occur at least quarterly. SAMS II is expected to replace the current SAMS version in the summer of 2008. To avoid a duplication of SAMS training and to lessen the burdens on Portfolio Advisors, SAMS documentation will not be required for Portfolio Advisors until SAMS II is in place. In other words, no training on the current version of SAMS will take place and no documentation is required on the current version of SAMS. Until SAMS II is in place, Portfolio Advisors should document their Portfolio Development at least quarterly in an MS Word document. Once SAMS II is on-line, the contents of the Word document can be inserted into the portfolio’s history on SAMS II and subsequent reports will be input directly on to SAMS. Portfolio Advisors should provide the Word document to their respective Network Champions and Portfolio Managers before the Network calls. In addition to providing a template for an action plan, Attachment A also serves as a useful template for Portfolio Advisors to follow when documenting and reporting on their portfolios during this interim period before the completion of SAMS II.

































TAS Continuous Improvement Cycle - Portfolios

1. Define - Build a technical foundation on the portfolio issues, the NTA’s position, the IRS’s position and stakeholders and issues.
2. Measure – Analyze the issue’s current state. Develop a network of contacts and information sources.
3. Analyze – Using data, determine potential causes of barriers to performance.
4. Improvement Actions – Initiate advocacy projects, immediate interventions, recommend and work on or with task forces or Report to Congress Most Serious Problems teams.
5. Control – Monitor process and measure results to determine if improvements have desired impact and are repeated over time.

Flow Chart for Reviewing Internal Management Documents (IMDs)

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IMD Review Template

SAMS PROJ. #: IDXXXXX (edit number) DATE: date of your review TIME: time you spent doing the review
REVIEWER: Taxpayer Advocate Service (add your name and title)
CONTACT: TAS IMD/SPOC Program Manager. Please copy *TAS IMD SPOC mailbox when you respond.
We are suggesting the following changes and/or clarifications
IRM Subsection (or Other Document Paragraph Number) and Page Number CURRENT TEXT (Enter the current draft text related to your comment)(Enter Taxpayer Rights and Taxpayer Burden Issues in bold up to 250 characters per recommendation)


Rec #1 – TP Burden- Requiring both spouses to be present to e-file
Rec #2 – TP Rights – Omitting IA fees exceptions for low income taxpayers

TP Rights or TP Burden? (If yes, place an "x" in this column.) TAS COMMENTS and RECOMMENDATIONS Operating Division Response to TAS Comments/ Recommendations
(IMD Use Only)
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IMD Process Quality Review Criteria

TIMELINESS (T) – 6 Attributes
T1 Did IMD Support Staff enter the review on SAMS and notify the IMD Analyst & IMD/ SPOC in a timely manner? IRM (07–09) For new reviews, once the new review is received in the *TAS IMD SPOC mailbox, it must be entered on SAMS and the IMD Analyst & IMD/SPOC must be notified of the new review so that pre-screening may begin.
IMD - 2 business days from the email received date - "Actual Start Date"
OTHER - 3 business days from the "Actual Start Date"
This attribute is applicable to all IMD Reviews and OTHER: SPOC Reviews. This attribute is rated as N/A in the following situations:
• The review is recalled or a duplicate
T2 Did IMD Analyst perform the abbreviated review, including responding to the submitter if no response or limited response, and notify the IMD/SPOC and IMD Support staff in a timely manner? IRM 13.2.1 5 (07–09) For both IMD and SPOC comprehensive reviews, a decision that a review is comprehensive, shown by the posting of the review to SAMS and the assignment of reviewers to the review, must be made within 4 business days. If the decision is that an abbreviated review is sufficient, the review must be completed with a response to the submitter within 30 calendar days unless the submitter agrees that contact dates may be lengthened or shortened. This attribute is applicable to all IMD Reviews and SPOC Reviews. This attribute is rated as N/A in the following situations:
• The review is submitted for closure within 30 days of the initial contact, or
• No contact information is available
T3 Did the IMD Analyst post the comprehensive review to the SAMS site and notify all reviewers of the review in a timely manner? IRM (07–09) The first step in working a comprehensive IMD or SPOC Review is notifying the reviewers of the review assignment and the due date for responding. The review is posted to the SAMS site and Case Advocacy managers, Technical Liaisons. etc., assigned. Non-SAMS users, receive the review via email from the *TAS IMD SPOC mailbox. This must be done within 4 business days of the initial receipt of the review. This attribute is applicable in all comprehensive IMD and SPOC reviews.
T4 Did the reviewers forward their completed reviews to the IMD staff in a timely manner? IRM (07–09) Action dates will be revised as needed to ensure resolution of the issues of the review. Revised action dates will be documented by analyst on SAMS Task. Tasks for IMD and SPOC reviews are dates when:
(1) the review is due to the IMD/SPOC and
(2) the dates when the review is due to the originator (the Operating Division author, usually).
The general rule is that the review must be completed by the reviewer with a response to the IMD/SPOC within 14 days of their business unit being notified of the review by being posted on the SAMS site or by email from IMD staff unless the submitter agrees that contact dates may be lengthened or shortened.
• If a review is sent expedite with a shortened timeframe noted, that timeframe should be used.
• If additional time is needed, the IMD/SPOC should notify the originator and obtain approval.
This attribute is applicable for all IMD and SPOC reviews.
T5 Did the IMD/ SPOC prepare the finalized consolidated review in a timely manner? IRM (07–09) IMD/SPOC is required to prepare a signed Form 2061 and a consolidated, edited version of the reviews received from the various reviewers within 7 days of receipt all completed reviews. If the consolidated review contains elevated criteria, the IMD/SPOC has 9 days from receiving the completed reviews to elevate the proposed response via email to manager. At that time, the IMD/SPOC needs to either
• Ensure that 5-10 calendar days are left on the due date, or
Request an extension from the originator, beyond the original 30 calendar days normally provided. .
This attribute is applicable in most IMD and SPOC reviews. However, circumstances may exist under which one or both of the documents are not required. If the review is elevated, the Form 2061 would not be required until final approval is given by the Director, II.
This exception would result in a rating of N/A for the Form 2061 portion of this attribute.
T6 Were all substantive actions taken on the review in such a way to progressively move it toward resolution? IRM (07–09) . A review must be worked with no unnecessary delays or periods of inactivity.
Responsibilities for IMD/SPOC and/or staff members include:
• Monitoring the progress of the review,
• Monitoring the progress of the review to ensure that deadlines are met and completing tasks by these established deadlines,
• Communication with IMD staff and reviewers on progress of work,
• Coordinating activities of IMD staff.
Management officials should be monitoring SAMS to give appropriate guidance and thus help move the review along to resolution.
IMD Staff is normally allowed 30 days to complete each review, as necessary; however, reviews may be shortened or lengthened with originators consent.
This attribute is applicable in all IMD and SPOC reviews.
ACCURACY (A) – 5 Attributes
A1 Did the Reviewer fill out the IMD review template correctly and completely? IRM (07–09) . The IMD Review template must include the following items:
• The number and title of the document
• The date of review,
• the time spent on the review,
• the name of the reviewer.
• Identification of the subsection or paragraph being addressed, including the IRM page number,
• the current language in the draft document and
• the recommended change for that item.
This attribute is applicable in all IMD and SPOC reviews.
A2 Was SAMS updated appropriately by IMD staff as to status and tasks? By reviewer as to research (if a SAMS user)? If reviewer was not a SAMS user, did they request the IMD staff do the update? IRM (07–09) Reviewers who are SAMS users should:
• Update the status of the review on SAMS from "Pending Assignment" to "In Process"
• Update the work flow on SAMS to indicate their findings, providing the same information they provided on the IMD Review Template (see A1 above).
Note: If the reviewer is not a SAMS user, they should forward the SAMS template to the *TAS IMD SPOC mailbox and request the IMD Staff to do the input on SAMS until they can obtain their manager's approval on Form 5081 for SAMS access.
This attribute is applicable in all IMD and SPOC reviews.
A3 Did the consolidated response accurately capture the feedback provided by the reviewers? IRM (07–09) . The IMD/SPOC Prog Mgr. should clarify any unclear feedback with the reviewer to confirm the content of the feedback and the language to be used in consolidating the reviews. If differing positions are present, the IMD/SPOC should determine from the facts presented the accurate TAS position. This attribute is applicable in all IMD and SPOC reviews.
A4 Did the review disclose a systemic issue or was it related to an MSP or current Objective? Was it appropriately considered for elevation? IRM (07–09) . A systemic issue impacts a segment of taxpayers locally, regionally, or nationally. These issues involve systems, processes, policies, procedures, or legislation and require study, analysis, recommendations, and action to effect positive results. Systemic issues involve protecting taxpayer rights, reducing or preventing taxpayer burden, ensuring equitable treatment of taxpayers or providing essential services to taxpayers. This attribute is applicable in all IMD and SPOC reviews.
A5 Were tax law and IRM/IRS procedures correctly applied and interpreted? IRM (07–09) Proper application of statutes and administrative regulations to the facts and circumstances as well as the correct interpretation of relevant internal guidelines. This attribute is applicable for all IMD and SPOC reviews that involve tax law or procedural requirements. This attribute is rated as "N/A" for those with no tax law or procedural impact.
COMMUNICATION (C) – 5 Attributes
C1 Did the reviewers provide timely, clear, logical and grammatically correct feedback in their review response? IRM (07–09). • Reviewer feedback should be grammatically correct and follow chronological progression relative to the document being reviewed.
• The contents should be clear and readily understandable.
• Timely feedback is necessary. See timeliness attributes above.
This attribute is applicable in all elevated IMD and SPOC reviews.
C2 Did the IMD staff provide a consolidated response to the OD that clearly relates TAS’s position on the issues? IRM (07–09) . • The IMD/SPOC Program Mgr. should make appropriate contacts to ensure that the position presented in the consolidated review accurately portrays and communicates the TAS position of the issue. This attribute is applicable in all elevated IMD and SPOC reviews.
C3 Was managerial concurrence of the elevated issue obtained and was managerial feedback timely? IRM (07–09) . • This attribute measures both the managerial involvement AND the timeliness of the managerial action. Both components of this attribute must be met in order for the attribute to be rated as met. Document review on SAMS.
• Review and feedback provided within 7 calendar days of notification of elevated issue availability re email to manager.
This attribute is applicable in all elevated IMD and SPOC reviews.
C4 Was there contact and coordination with the appropriate internal and external stakeholders as required by the review? IRM (07–09) . Individuals/teams may need to consult Attorney Advisors, LITC, TAP, CNTA, Sr. Advisor to NTA, Portfolio Advisors, TAG, C & L, and TAS Research This list is not all inclusive. This attribute is applicable on all IMD and SPOC reviews.
C5 Did the IMD staff take appropriate steps to relate issues that required actions to be taken? IRM (07-09) . Finalization and resolution of a review may require that TAS (though Systemic Advocacy) provide education or communication of changes or clarifications to various stakeholders. Appropriate channels include contacting NCAG for forms changes, contacting SPDER for internal IRM issues and certain TAS interim guidance issues, seeking clearance of issues through headquarters, postings to the TAS Homepage, www.irs.gov, items published in the Wednesday Weekly, etc. This attribute is applicable on IMD Reviews, SPOC Reviews, or other program issues that require outreach/education or change spearheaded by the IMD/SPOC program. This attribute is rated as "N/A" on all other projects.