)
或 https:// 表示您已安全连接到 .gov 网站。仅在官方、安全的网站上共享敏感信息。
- 13.2.5 Advocacy Projects
- 13.2.5.1 Program Scope and Objectives
- 13.2.5.1.1 Background
- 13.2.5.1.2 Authority
- 13.2.5.1.3 Roles and Responsibilities
- 13.2.5.1.4 Program Management Review
- 13.2.5.1.5 Program Controls
- 13.2.5.1.6 Terms & Acronyms
- 13.2.5.1.7 Related Resources
- 13.2.5.2 Safeguarding Taxpayer Information
- 13.2.5.3 Working an Advocacy Project
- 13.2.5.3.1 Advocacy Project Assignment
- 13.2.5.3.2 Team Composition and Responsibilities
- 13.2.5.3.3 Initial Project Documentation
- 13.2.5.3.4 Ongoing Project Documentation
- 13.2.5.3.5 Project Status Updates
- 13.2.5.3.6 Next Contact and Follow-up Dates
- 13.2.5.3.7 Working Project Steps
- 13.2.5.3.8 Project Development
- 13.2.5.4 Elevating Issues to the Deputy Executive Director, Systemic Advocacy, Technical Advocacy (DEDSA-TA) and the Executive Director, Systemic Advocacy (EDSA)
- 13.2.5.4.1 Project Resolution
- 13.2.5.4.1.1 Administrative Procedure Changes
- 13.2.5.4.1.2 Published Guidance Proposal
- 13.2.5.4.1.3 Legislative Recommendation Proposal
- 13.2.5.4.1 Project Resolution
- 13.2.5.5 Closing an Advocacy Project
- 13.2.5.5.1 External Submitter Closing
- 13.2.5.5.2 Internal Submitter Closing
- 13.2.5.5.3 Closing Communications
- 13.2.5.5.4 Phoenix Closing Actions
- 13.2.5.5.4.1 Recommendations
- Exhibit 13.2.5-1 TAS Research Request
- Exhibit 13.2.5-2 Memorandum to Request a Counsel Legal Opinion
- Exhibit 13.2.5-3 Advocacy Closing Letter Template
- Exhibit 13.2.5-4 Project Closing Email Template for Internal Submitters Only
- Exhibit 13.2.5-5 SA Quality Attributes
- 13.2.5.1 Program Scope and Objectives
Part 13. Taxpayer Advocate Service
Chapter 2. Systemic Advocacy
Section 5. Advocacy Projects
13.2.5 Advocacy Projects
Manual Transmittal
August 10, 2026
Purpose
(1) This transmits an update to IRM 13.2.5, Systemic Advocacy, Advocacy Projects.
Background
TAS Systemic Advocacy (SA) plays a vital role in identifying, analyzing, and resolving broad-based taxpayer problems. Projects emerge from several sources including but not limited to, TAS employees, IRS employees, taxpayers, practitioners, and other external stakeholders.
SA utilized the Phoenix platform to receive, manage, document, and monitor systemic issues and projects. SA is engaged in the evaluation and resolution of submissions taking prompt and efficient action to address matters of taxpayer rights and the reduction of burden.
Material Changes
(1) IRM 13.2.5.1, Program Scope and Objectives, updated language and removed reference to IRM 1.11.6.6, - IPU 25U0251 issued 02-27-2025
(2) IRM 13.2.5.1.1, Background, superseding IPU 25U0251 issued 02-27-2025 editorial changes made updating overview of the program.
(3) IRM 13.2.5.1.2, Authority, removed § symbol and corrected title of IRM 11.3.1 - IPU 25U0251 issued 02-27-2025
(4) IRM 13.2.5.1.3, Roles and Responsibilities, corrected JRC and ARC references and removed referenced to advocacy proposal - IPU 25U0251 issued 02-27-2025
(5) IRM 13.2.5.1.4, Program Management Review, remove reference to Exhibit 13.2.5-7 and Intermediate Interventions (II) as this process is obsolete - IPU 25U0251 issued 02-27-2025.
(6) IRM 13.2.5.1.5, Program Controls, removed Business Objects Enterprise (BOE) as it is being replaced by the Phoenix System and removed reference to Advocacy Proposal, process obsolete - IPU 25U0251 issued 02-27-2025.
(7) IRM 13.2.5.1.6, Terms & Acronyms, changed language for clarity and removed reference to Exhibit 13.2.1-1 - IPU 25U0251 issued 02-27-2025.
(8) IRM 13.2.5.1.7, Related Resources, removed reference to SAMS, added site title with the link and corrected the titles of the IRMs referenced - IPU 25U0251 issued 02-27-2025
(9) IRM 13.2.5.2, Safeguarding Taxpayer Information, Corrected title reference for IRM 11.3.1 - IPU 25U0251 issued 02-27-2025
(10) IRM 13.2.5.3, Working an Advocacy Project, Added reference to IRM 13.2.3.3, - IPU 25U0251 issued 02-27-2025
(11) IRM 13.2.5.3.1, Advocacy Project Assignment, changed language for clarity. Changed Project Team Lead to Project Owner and Project Manager to Project Director. Removed reference to teams. Also, Removed any reference to Systemic Advocacy Management System (SAMS) - IPU 25U0251 issued 02-27-2025.
(12) IRM 13.2.5.3.2, Team Composition and Responsibilities, Added EDSA approval for project closures worked by technical liaisons and removed team member’s responsibilities. Removed any reference to SAMS. Also corrected team composition - IPU 25U0251 issued 02-27-2025.
(13) IRM 13.2.5.3.3, Initial Project Documentation, Changed process for initial actions and provided clarity on Subject Matter Expert Referrals (SMEAR). Removed any reference to SAMS and to TAMIS. The note was removed. Added note to indicate case advocacy histories may be obtained. Updated to show changes in the streamlined initial contact process. And removed all reference to Action Plan until a later Phoenix release. Also, provided new process for requesting additional case examples from the Technical Analysis and Guidance (TAG) group, IPU 24U1168 issued 11-29-2024 is superseded by IPU 25U0251 issued 02-27-2025
(14) IRM 13.2.5.3.4, Ongoing Project Documentation, Removed any reference to SAMS, deleted bullet points that are obsolete and updated the Note from Files to Documents Upload - IPU 25U0251 issued 02-27-2025.
(15) IRM 13.2.5.3.5, Project Status Updates, Removed any reference to SAMS and unnecessary information. Updated language for clarity and added a note, IPU 24U1168 issued 11-29-2024 is superseded by IPU 25U0251 issued 02-27-2025.
(16) IRM 13.2.5.3.6, Next Contact and Follow-up Dates, Replaced reference to team lead with project owner. Removed reference to SAMS. Added new information for clarification and removed note - IPU 25U0251 issued 02-27-2025.
(17) IRM 13.2.5.3.7, Working Project Steps, Changed language for clarity and removed Advocacy Tip - IPU 25U0251 issued 02-27-2025.
(18) IRM 13.2.5.3.8, Project Development, throughout the section changed language for clarity and new guidance, added reference to Exhibit 13.2.5-1, removed multiple § symbols, and any reference to SAMS or TAMIS - IPU 25U0251 issued 02-27-2025.
(19) IRM 13.2.5.3.8 (3), Project Development, Clarified the research scope, - IPU 24U1168 issued 11-29-2024.
(20) IRM 13.2.5.3.8 (5), Project Development, Modified content for clarification - IPU 24U1168 issued 11-29-2024.
(21) IRM 13.2.5.3.8 (8), Project Development, Update the Note: Advocacy Tips to show guidance, - IPU 24U1168 issued 11-29-2024 is superseded by IPU 25U0251 issued 02-27-2025.
(22) IRM 13.2.5.4, Elevating Issues to the Deputy Executive Director, Systemic, Advocacy, Technical Advocacy (DEDSA-TA) and the Executive Director, Systemic Advocacy (EDSA), Replaced reference to manager with director. Changed language for clarity - IPU 24U1168 issued 11-29-2024 is superseded by IPU 25U0251 issued 02-27-2025.
(23) IRM 13.2.5.4.1, Advocacy Proposals, Removed entire section as Advocacy Proposals are obsolete, superseding, - IPU 24U1168 issued 11-29-2024 with IPU 25U0251 issued 02-27-2025.
(24) IRM 13.2.5.4.1,1, Advocacy Proposal Memorandum, Removed entire section as Advocacy Proposal Memorandum are obsolete, - IPU 25U0251 issued 02-27-2025.
(25) IRM 13.2.5.4.1,2, Advocacy Proposal Briefing Document, Removed entire section as Advocacy Proposal Briefing Document are obsolete, - IPU 25U0251 issued 02-27-2025.
(26) IRM 13.2.5.4.2.1, Administrative Procedure Changes, is relocated and renumbered to IRM 13.2.5.4.1.1, with editorial changes removing ARC Potential Topic Submission form, removing paragraph 3(a) due to ineffectiveness, and updated reference of SAMS to Phoenix - IPU 24U1168 issued 11-29-2024 is superseded by IPU 25U0251 issued 02-27-2025.
(27) IRM 13.2.5.4.2.3, Legislative Recommendation Proposal, is relocated and renumbered to IRM 13.2.5.4.1.3 with editorial changes removing ARC Potential Topic Submission form and paragraph (3) due to ineffective process - IPU 25U0251 issued 02-27-2025.
(28) IRM 13.2.5.5, Closing an Advocacy Project, Changed Project Team Lead to Project Owner, Project Manager to Project Director, replaced reference to SAMS with Phoenix, updated language for clarity, and removed paragraphs 3 - 5 due to Phoenix automating that process - IPU 25U0251 issued 02-27-2025.
(29) IRM 13.2.5.5.1, External Submitter Closing, Replaced reference to "Notes" tab with Phoenix "task" and reference to SAMS with Phoenix - IPU 24U1168 issued 11-29-2024 is superseded by IPU 25U0251 issued 02-27-2025.
(30) IRM 13.2.5.5.2, Internal Submitter Closing, Replaced reference to "Notes" tab with Phoenix "task", changed reference to SAMS with Phoenix, and added title for Exhibit.13.2.5-4, - IPU 25U0251 issued 02-27-2025.
(31) IRM 13.2.5.5.4, SAMS Closing Actions, Updated section title to read Phoenix Closing Actions, replaced references to manager with director, team lead with project owner, added a note, and updated the closing review process - IPU 24U1168 issued 11-29-2024 is superseded by IPU 25U0251 issued 02-27-2025.
(32) IRM 13.2.5.5.4.1, Closed Project Status, updated section title to read Recommendations. Updated Phoenix closing process as it relates to Advocacy Project recommendations and removed outdated language due to Phoenix automation process - IPU 25U0251 issued 02-27-2025.
(33) Exhibit 13.2.5-1, TAS Research Request, New guidance added for Research Request - IPU 25U0251 issued 02-27-2025.
(34) Exhibit 13.2.5-3, Advocacy Closing Letter Template, Removed any reference to SAMS - IPU 24U1168 issued 11-29-2024 is superseded by IPU 25U0251 issued 02-27-2025.
(35) Exhibit 13.2.5-4, Project Closing Email Template for Internal Submitters Only, Removed any reference to SAMS - IPU 24U1168 issued 11-29-2024 is superseded by IPU 25U0251 issued 02-27-2025.
Effect on Other Documents
IRM 13.2.5, Systemic Advocacy, Advocacy Projects, dated 10-20-2022 is superseded. This IRM incorporates the following IRM Procedural Updates (IPU’s): IPU 24U1168 issued November 29, 2025 and IPU 25U0251 issued February 27, 2025.
Audience
Taxpayer Advocate Service, primarily employees within Systemic Advocacy (SA).
Effective Date
(08-10-2026)
Adam Morse
Covering Executive Director Systemic Advocacy
- This IRM section describes the types of Advocacy Projects (APs) used by Systemic Advocacy (SA) and the process for working projects. The APs are worked to research, validate and resolve systemic issues. They are worked to affect change and to propose alternative language to an IRM using an Outside the Clearing Process (OCP) form.
- Audience: Taxpayer Advocate Service, primarily employees within Systemic Advocacy (SA).
- Policy Owner: National Taxpayer Advocate (NTA), TAS
- Program Owner: Executive Director Systemic Advocacy (EDSA)
- Contact Information Employees should contact the Product Content Owner provided on the Product Catalog Information page for this IRM. To recommend changes or make any other suggestions related to this IRM section.
- Throughout the Taxpayer Advocacy Service (TAS), employees play a vital role in identifying, analyzing, and resolving broad-based taxpayer problems. These taxpayer problems come to TAS’s attention through several sources including offices within TAS, Internal Revenue Service (IRS) employees, taxpayers, practitioners, and other external stakeholders.
- TAS SA plays a vital role in identifying, analyzing, and resolving broad-based taxpayer problems. Projects arise from several sources, including field offices within TAS, IRS employees in other functions, and external stakeholders.
- SA has replaced Systemic Advocacy Management System (SAMS) with the Phoenix system to receive, control, document, and monitor systemic issues and advocacy projects. The staff is engaged in the evaluation and resolution of issues and acts expeditiously to address matters of taxpayer rights and the reduction of burden.
- Internal Revenue Code (IRC) 7803(c) established the Office of the Taxpayer Advocate to assist with resolving problems with the IRS, identify areas in which taxpayers have problems dealing with the IRS, propose changes in the administrative practices of the IRS, and identify potential legislative changes to mitigate problems.
- The Executive Director Systemic Advocacy (EDSA) reports directly to the NTA. The EDSA is responsible for systemic advocacy oversight and the NTA's Objectives Report (also referred to as the June Report to Congress (JRC) and Annual Reports to Congress (ARC). The Deputy Executive Director Systemic Advocacy, Proactive Advocacy (DEDSA-PA) and the Deputy Executive Director Systemic Advocacy, Technical Advocacy (DEDSA-TA), are responsible for identifying and raising awareness of systemic issues impacting taxpayers. The DEDSA-PA is responsible for the production of the NTA ARC, the receipt and control of advocacy issues, and the internal management document process. The DEDSA-TA is responsible for the advocacy initiative tracking system, assignment of advocacy projects, and a database which captures advocacy projects, recommendations, and initiatives. TAS SA receives administrative and legislative proposals from a multitude of sources, including internal and external sources.
- Advocacy analysts assigned to SA work with the IRS Business Operating Divisions/Functional Units (BOD/FU) to analyze and understand the root causes of problems and support joint advocacy efforts. The ultimate goals of the advocacy analysts are to ensure the taxpayer’s fundamental rights are protected, IRS decisions consider taxpayer interest and the reduction of taxpayer burden, improve customer service, and address the inequitable treatment of taxpayers.
- SA has established a series of organizational measurements to address program effectiveness through direct oversight of three Technical Advocacy Directors (Collection, Examination and Processing). They are responsible for conducting reviews monthly as structured in the TAS Program Letter. In addition to these reviews, AP closures are reviewed by the Quality Review Program based on statistical sampling of closures.
Quality measures include:
- Accuracy - The correctness of actions defined by statute and guidance;
- Efficiency - The cost of producing a quality (accurate, complete, timely) product;
- Timeliness - Completing actions within time frames in statute and guidelines;
- Customer Satisfaction - Customer’s view of product provided;
- Employee Satisfaction - Employee’s view of work life; and
- Effectiveness - TAS’s success in resolving taxpayer’s problems.
- The standards fall within the following categories, Accuracy Focus, Procedural Focus, and Customer Focus with assigned attributes.
- The SA quality review of closed APs will provide organization performance measurement of the accuracy and timeliness of key SA product delivery.
Program Goals –The processes and procedures provided in this IRM are:
- To evaluate whether a submission is a systemic issue;
- To research and gather information to determine the potential impact on taxpayers and on processes and procedures impacting the Taxpayer Bill of Rights (TBOR), and;
- To evaluate proposed procedural changes initiated by the Business Operating Division/Functional Units (BOD/FU) and submit recommendations.
- Program Reports – SA uses Phoenix System for the reporting of program objectives.
- Annual Review –The three Directors of Technical Advocacy (Examination, Collection, and Processing) are responsible for reviewing the information in this IRM annually to ensure accuracy and promote consistent tax administration. The Director of Advocacy Efforts (DAE) has the responsibility for oversight of the yearly program reviews.
- A list of Terms and Acronyms is located in IRM 13.2.1, Terms and Acronyms.
Additional SA program information and resources are available as provided below:
- TAS, SAMS Systemic Advocacy Site
- IRM 13.2.1.5.1, IMD/SPOC Reviews;
- IRM 13.2.1, Systemic Advocacy Overview;
- IRM 13.2.3, Evaluating and Reviewing Systemic Issues; and
- IRM 13.2.7, Collaborative Teams
- IRM 13.2.8, National Taxpayer Advocate’s Annual Reports to Congress (ARC).
- IRC 6103(a) prohibits unauthorized disclosure of tax returns and return information.
- TAS employees must be aware of information that must be protected, how to protect it, and how to dispose of or destroy the information when it is no longer required.
- Taxpayers can expect TAS to keep their information confidential and only share information when necessary and only as authorized by law. See IRC 7803(c)(4)(A)(iv); IRM 13.1.5, Taxpayer Advocate Case Procedures, Taxpayer Advocate Service (TAS) Confidentiality; and IRM 1.2.1.2.1, Policy Statement 1-1, Mission of the Service.
- IRM 1.15.2, Records and Information Management: Types of Records and Their Life Cycle provide specific guidelines and procedures for safeguarding and disposing of protected records.
- For more information about IRC 6103, see IRM 11.3.1, Introduction to Disclosure.
An AP is designed to:
- Identify and address systemic and procedural issues;
- Analyze the underlying causes of problems, and;
- Propose corrective action.
- SA uses an AP as a vehicle to identify and resolve a systemic problem and affect change, see IRM 13.2.3.3, What is a Systemic Issue? The problem could involve the burden or effectiveness of current procedures and processes, consistency with statutory requirements, or communications and products offered to the public. Employees are expected to work APs with a sense of urgency by taking significant actions monthly, but no less than once every 31 calendar days.
- The section below provides guidance on working an AP from assignment to closure.
- Systemic Issue Review and Evaluation (SIRE) reviewers complete the review process and may propose a project be created from those issues deemed to be potentially systemic. For additional information, see IRM 13.2.3, Evaluating and Reviewing Systemic Issues.
The technical advocacy director assigns the project to a project owner. (On Phoenix, the technical advocacy director is shown as the "Project Director" ).
Note:
The Technical Liaison (TL) Director has the option to use Phoenix as a tool to track or record projects assigned to TLs. The TL Director is also shown as a "Project Owner".
- In Phoenix, the project director using the assignment date field assigns the project to the project owner. The workflow status is updated to "Assigned" .
On Phoenix, assignments are as follows:
- Project Owner;
- Project Director (SA Technical Advocacy Director or SA Technical Liaison Director);
- Deputy Executive Director Systemic Advocacy (DEDSA), and if required;
- Executive Director Systemic Advocacy (EDSA) for approval of project closures worked by technical liaisons.
The project owner’s responsibilities include:
- Completing the steps necessary to research and resolve the project’s issue(s);
- Keeping the project director informed of the project status.
The project director’s responsibilities include:
- Monitoring the progress of the project toward prompt resolution;
- Providing guidance for project resolution; and
- Keeping the DEDSA’s and SA management informed of the project status.
The DEDSA’s responsibilities include:
- Providing project resolution guidance; and
- Approval of final project resolution.
The project owner documents the initial actions on Phoenix within 31 calendar days of the assignment date.
Note:
If Advocacy Project is created from a Subject Matter Expert Assistance Request (SMEAR), ensure all relevant information is documented in Phoenix, including follow-up dates and next contact dates. Consider copying and pasting the relevant research from the SMEAR to the Advocacy Project as part of the initial project documentation.
- Document the review and document the information provided by the submitter and the issue review process including associated issues and/or work types.
Complete an initial review of authorities. Review and list the IRM(s) or processes researched related to the issue. At a minimum document, Reviewed applicable IRMs.
Reminder:
Phoenix allows you to insert a link to a document, so you can have quick access to it easily.
Analyze examples, if available.
Review the initial examples that may include Phoenix case advocacy Example links or other information for a complete understanding of the issues involved. Confirm the examples supporting the issue.Note:
Phoenix Case Example links(s) may be obtained by sending a requesting email, outside of Phoenix, to with a Subject Line If needed, *TAS TAG Policy and Guidance with subject line: SA Phoenix Data Request. Request linkage of the specific Case Advocacy case. Once the Case Advocacy case Example link is updated, you should be able to view the Case Advocacy case along with the post information.
Contact the submitter.
The preferred method of contact is a telephone call. If telephone contact is not an option, contact the submitter via their email address.During this initial contact:
• If the submitter is not an IRS employee, the project owner must provide the necessary identifying information as required by IRM 13.1.2.4.1, Identify Yourself;
• Advise the submitter the project is being worked and they will be notified of the outcome upon conclusion;
• Confirm with the submitter a clear understanding of the issue;
• Ask if there is additional information or if changes have occurred affecting the issue;
• Team Lead should discuss frequency of subsequent contacts. The next contact date defaults to 31 calendar days (including if no contact is necessary until close), document the next contact date and submitters preference for closing contact;
• The next contact date defaults to 31 calendar days of the previous contact with the submitter if a subsequent contact is not documented.
• Document Phoenix of the attempted contact(s);
• Explain it may be necessary to contact the submitter again if there are additional questions;
• If the submitter states that they no longer need to be contacted or that they only want to be contacted once the project has been closed, make a notation of this in Phoenix;
• Explain to submitter they will be notified of the outcome at the conclusion of the project;
• Encourage the submitter to contact team lead for status updates, if desired;
• Confirm submitter’s preferred communication for sharing project outcome:- Internal submitters: Email or phone;
- External submitters: Phone or closing letter; and
Exception:
No contact is required: when the project owner is the submitter, when a TAS employee inputs a submission to Phoenix for someone else, or TAS is unable to locate the submitter’s information.
If the submitter is external, and only an email address is provided, then use the recommended language:
"I will be working on the issue you submitted to the Phoenix System. I’d like to explain the next steps. Please contact me at XXX-XXX-XXXX during the hours of XX:XX AM to XX:XX PM (Time Zone). If you prefer, provide me a phone number and the best time to reach you.
In order to ensure your privacy, we discourage you from sending your personal information to us by email. Further, the IRS does not allow employees to exchange unencrypted personally identifiable or other sensitive information with email accounts outside of the IRS network, even with your permission."
- Document your research. Phoenix has a section called "Project Research", the Project Owner has the option to document their research there or post it in the project feed.
Document all actions and information that affect the outcome of the project as follows:
- Take and document substantive actions;
- Briefly describe the action taken, the information secured, barriers, advocacy opportunities, and the impact on the project;
- Summarize emails or documents unless the entire email or document is relevant as an explanation; and
- Do not enter tax return information on Phoenix.
- Document your research. Phoenix has a section called Project Research, the Project Owner has the option to document their research there or post it in the project feed.
Note:
Attach only the relevant portion of documents to "Document Upload" section. Avoid attaching entire IRMs or other large documents.
Document a status update by the last working day of the month when working projects.
Use the following format for status updates on Phoenix:- Issue : This is a brief re-stated description of the issue, purpose of the AP and its potential direction, if known. This description may be updated over time;
- Cause(s): Describe the possible causes of the issue, if known. Eliminate or add causes as the project progresses;
- Actions to Date: Briefly describe important actions to date. Include research, communications with the IRS or other stakeholders, and other relevant information ; and
- Actions Remaining: Describe actions remaining to resolve the issue. Include actions TAS needs to take, as well as actions the IRS needs to take. These actions change throughout the life of the project. If applicable, identify potential barriers to resolution.
- If at any point the project is reassigned, the new project owner must contact the submitter by the already set NCD by the outgoing project owner or within 31 calendar days of the last action taken if no NCD set.
- If no NCD is documented, it automatically is set for 31 calendar days from the date of the last contact with the external submitter; unless it was previously documented that contact was not wanted/required.
Follow−up dates (FUDs) act as reminders to take action and move the project towards resolution. The expectation is the project owner will take a substantive action as the AP dictates and allows. The project owner will document when the AP requires longer than a month between substantive actions. FUDs are normally no more than 31 calendar days from the last FUD. Consider competing priorities and scheduled leave when setting follow up dates.
Exception:
When there is no expected action required within 31 calendar days, e.g., TAS Research needs 60 days to complete requests and all other actions are completed, document in Phoenix the reason for the extended date.
Document FUD in Phoenix . Set specific calendar dates and do not use an estimated completion date or a non-specific date such as "the week of…"
Example:
Initial project documentation completed July 1. The FUD documented would be either August 1st or earlier. (e.g., "Complete review of related IRC section by August 1st."
Projects generally progress through the following steps:
- Researching how the existing process works, often via contact with the process owners;
- Determining where in the process the problem exists;
- Reviewing the issue with the process owner;
- Comparing the process against existing IRS requirements;
- Analyzing various courses of action; and
- Recommending and negotiating improvements with the IRS.
Note:
If the agreed resolution is significant, consider negotiating with the IRS to issue a Servicewide Electronic Research Program (SERP) Alert to employees.
Completing the above steps in IRM 13.2.5.3.7, Working Project Steps could require additional information not available from the submitter or the issue review process. This additional information is not limited to, but may include:
- Internal TAS Coordination;
- Project Research and Collecting Data;
- Locating the Process Owner;
- Determining the Scope of the Potential Systemic Issue;
- Legal Resources; and;
- Negotiating for Systemic Improvements
Internal TAS coordination is appropriate when other offices may have information that will assist with the resolution of the issue. In turn, information on the project may assist other offices in their advocacy efforts. When the issue involves coordination with other TAS stakeholders, the project owner may coordinate with one or all of these TAS internal stakeholders. Additional contacts may include, but are not limited to the following:
- Internal Management Document/Single Point Of Contact (IMD/SPOC);
- TAS collaborative efforts;
- Technical Analysis and Guidance (TAG);
- Low Income Taxpayer Clinic Program (LITC) Office;
- Taxpayer Advocacy Panel (TAP) Program Office;
- Internal Technical Advisor Program (ITAP);
- Attorney Advisors (AA); and
Office of the Division Counsel/Associate Chief Counsel (National Taxpayer Advocate Program) (CNTA).
Researching and Data Collecting provides various methods or alternatives for securing information and data to assist in researching the issues and determining the scope. Below are suggestions to assist in researching and data gathering:
- Research other TAS activities, including but not limited to, ARC, Phoenix, Research Studies, and Collaborative Team Efforts. For example, ARC MSPs may contain legal references;
- Discuss with the project manager. If the project manager agrees, consider consulting with a SME, AA or TL;
- Request case examples from case advocate inventories by submitting a TAS Communications Assistance Request (CAR). Additionally, consider requesting TAG to include a message on the relevant Knowledge Article feedback process; ;
- Consider contacting submitters of related issues associated with the project for additional examples;
- Complete a Technical Advice Assistance Request (TAAR) for assistance from the ITAP. Route the TAAR through the project manager to ITAP;
- Tax administration stakeholders, such as Treasury Inspector General for Tax Administration (TIGTA), General Accountability Office (GAO), Information Reporting Program Advisory Committee and the Office of Research websites may provide background information and potential contacts;
- Consider a Data Collection Instrument (DCI) if applicable; and
- Research IRS and other additional external websites. Examples include, but are not limited to: Servicewide Notice Information Program (SNIP), SERP, Congress.gov, Document 6209 and Lexis−Nexis.
Locating the Process Owner
There are several options for identifying the author of an IRM, form, letter, notice, or publication including:- SERP contains a listing of IRM authors and can be found at this website. SERP IRM Authors;
- IRS produces a monthly update of IRMs alphabetically and in order by number, owner, and those that are obsolete. The list can be found at this website. Product Catalog Information;
- Research the Taxpayer Correspondence Services and SNIP for copies and descriptions of notices, which also provide the responsible notice "owner" and volume data;
- Research BOD web pages for information and potential contacts;
- Research the Tax Forms and Publications web page for information about locating an existing product; and
- Research Media and Publications web page for information about locating the author of a letter. Find a Specialist;
Determining the Scope of the Potential Systemic Issue could include:
TAS Research: Complete an internal TAS Research request on the TAS SharePoint™ site and forward to your project manager for approval.
Example:
If information is needed to determine the number of taxpayers affected by a systemic issue in order to correct the accounts, complete an Internal TAS Research request on the TAS SharePoint™ site and forward to your project director for approval. Exhibit 13.2.5-1, TAS Research Request
- Statistics of Income (SOI) provide statistical data by type of taxpayer, by form, by year, and by custom sorts;
Legal resources that should be considered when working a project include:
- Library of Congress;
- Congress.gov is the official website for U.S. federal legislative information. The site provides access to accurate, timely, and complete legislative information for Members of Congress, legislative agencies, and the public, and includes items such as public laws, committee reports, conference reports, etc.;
- Lexis-Nexis or Westlaw Research case law, state and federal statutes, administrative codes, newspaper and magazine articles, public records, law journals, law reviews, treatises, legal forms and other information resources;
- Internal Revenue Bulletin (IRB) is the authoritative instrument for announcing official rulings and procedures of the IRS and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, and court decisions;
Seeking Legal Advice for Formal Counsel Opinion concerning a recommended course of action.
Example:
This could include addressing whether an IRS procedure or practice is consistent with the tax code.;
- The CNTA generally provides legal advice regarding project work. Consult with project director on the need for a legal opinion. See IRM 13.1.10.2, , for additional information;
- As part of the Office of the Division Counsel/Associate Chief Counsel (National Taxpayer Advocate Program), the CNTA is responsible for providing legal interpretations of:
• IRC 7526, LITCs;
•IRC 7803(c), Office of the Taxpayer Advocate, including the LTA’s discretion not to disclose to the IRS contact with, or information provided by, the taxpayer;
• IRC 7811, Taxpayer Assistance Orders;
• Taxpayer Advocate Directives;
• IRC 7803(a)(3), Taxpayer Bill of Rights;
• The scope of TAS's statutory authority or delegated authority; and
• Issues regarding TAS legislative proposals or any other matter related to the NTA's ARC. - Prepare a memo requesting a legal opinion if legal advice is needed and route through the project director. Exhibit 13.2.5-2, Memorandum to Request a Counsel Legal Opinion. All written requests for CNTA assistance must be routed through a manager and the DEDSA-TA for approval.; and
- In the rare instance legal advice is necessary on an individual case, contact the Small Business/Self-Employed (SB/SE) Counsel office. See the link on the CNTA website for SB/SE Contacts for TAS. Counsel to the National Taxpayer Advocate.
Identifying New Systemic Issues
In the course of working the project, the project owner may discover new issues not initially identified. For example, the project deals with a processing problem and the project owner learns of an additional problem elsewhere in the processing pipeline. Discuss possible options with the project director:- If issues relate to the core systemic problem, then consider expanding project scope;
- If the new issue is unrelated and potentially systemic, then input the new issue to Phoenix; and
- If the new issue is unrelated and systemic, then submit the issue on Phoenix requesting creation and assignment of the project.
Negotiating Systemic Improvement
Once there is an understanding of the systemic problem, identify potential barriers, possible remedies, and advocate for the needed systemic improvements by working with the appropriate IRS staff. Supporting information or data that may help in convincing the IRS to accept the recommendations could include, but are not limited to the following:- Evidence that a process is not working as intended, such as case examples;
- Demonstrating the current process costs the IRS more than the recommended process;
- Analysis showing how IRS procedures are inconsistent with the Code or Congressional intent;
- Scope of the number of impacted taxpayers and financial burden;
- Explanation on how a change supports the TBOR;
- Locate examples from Treasury Regulations that support recommendations.
Advocacy Tips:
- While recommendations must be documented, negotiations are often the result of back and forth discussions rather than one formal recommendation. Negotiations should be conducted at the analyst level and various factors should be considered when deciding to elevate issues to the program, executive or NTA level;
- Consider discussing IRS’s response to the recommendation with the submitter. The submitter may have additional information to assist in rebutting the IRS position;
- Discuss with the project manager. If the project manager agrees, consider consulting with a SME, AA or TL;
- Depending on the issue, consider contacting the CNTA, TAG, IMD/SPOC, or a TAS SME to discuss the issue and ideas for rebutting the IRS; and
- Consider researching intranet sites to view IRS data and/or information to incorporate IRS data into recommendations. The approach of quoting IRS information/data may assist in acceptance of the recommendation.
- There may be times the IRS does not agree to our recommendations. Discuss this with the project director. If the project director agrees with the recommendations, elevate the issue to the appropriate functional Technical Liaison (TL). The TL can raise the recommendation at higher-level meetings. If the TL is unsuccessful, then consider elevating to DEDSA-TA/EDSA after discussing with the TL.
- The EDSA participates on executive level calls with the BODs. Depending on the issue, the EDSA may have an opportunity to discuss rejected recommendations. Discuss with the project director the possibility of elevating the issue. The project director will brief the DEDSA-TA and a decision will be made whether to elevate the issue.
Project resolutions are as unique as the issue itself. Consider the characteristics of the issue when selecting the resolution. Resolutions could include:
- Administrative procedure changes;
- Published guidance proposals; and
- Legislative recommendation proposals
- The IRS agreeing to change a process is the most common advocacy effort resolution. Agreements with the IRS can be resolved through telephone calls or emails and are informal. Request an email from the IRS to document verbal agreements. A formal written agreement is not necessary.
Document in the Phoenix "Recommendations" window significant recommendations made to the IRS. Update these recommendations as appropriate throughout the project. Examples of procedural changes include:
- Improved employee instructions;
- Process changes;
- Employee training; or
Combined with another type of advocacy work, such as an MSP or task force.
Note:
To avoid double counting, do not document in the Phoenix Recommendations window all recommendations made via the IMD/SPOC process, both through the normal review process and the out-of-clearance process. All IMD/SPOC Recommendations must be documented in Phoenix. All other recommendations are required to be input to the Phoenix Recommendations window.
Outside of Clearance Process (OCP) submissions are used to submit recommendations through IMD/SPOC to the BODs outside of the normal clearance process.
- Advise the BOD and complete the OCP template ;
- Email the template to *TAS IMD/SPOC.
If pursuing an IRM change through the OCP, follow these steps:
- Alert the IRM author TAS is proposing a change; and
- Email the OCP template to *TAS IMD/SPOC.
- If the proposed recommendation was discussed with the BOD, advise the BOD to expect an OCP as follow up to the conversation.
- If necessary, project owner may contact *TAS IMD/SPOC for guidance on completing the OCP template.
- See IRM 1.11.13, Taxpayer Advocate Service Internal Management Document and Single Point of Contact (TAS IMD/SPOC) Program for more guidance on the OCP.
Published guidance plays an important role in increasing voluntary compliance by clarifying ambiguous areas of the tax law:
- Promotes uniform application of tax laws;
- Promotes voluntary compliance;
- Reduces need for litigation;
- Provides guidance for new laws;
- Defines terms left undefined by Congress; and
- Sets record keeping & reporting duties.
Examples of published guidance include:
- Treasury Decisions;
- Revenue Rulings;
- Actions on Decisions;
- Notices;
- Announcements; and
- Other rulings and pronouncements.
When recommending the IRS to revise published guidance or issue new guidance:
- Gain management concurrence for the action;
- Highlight the problem;
- State why the IRS should change its position or issue new guidance; and
- In the case of new guidance, do not identify the type of published guidance needed. The CNTA will make that decision.
- Propose a legislative recommendation when changes may be necessary to improve equity or fairness in the tax code, improve service to taxpayers, or reduce taxpayer burden. While the IRS may change its own administrative policies or procedures, only Congress may enact or amend laws.
- Review recommendations with management concurrence prior to submitting the legislative change proposal to the ARC Office.
After determining the issue was not systemic or resolving the systemic issue(s), take the following steps to close the project:
- Discuss findings with the project director and document in Phoenix that the director approves project closure. Director or Project Owner will input in Phoenix that AP is ready for closure. This will start the 31 calendar day timeframe for Project Owner to submit for closure;
- Attempt to contact and discuss the outcome of the project with the submitter. You are not required to make contact with submitters of issues that were associated to the project after it was created or associated submitters when there are multiple issues submitted and contact of all submitters is overly burdensome. See below IRM 13.2.5.5.1, External Submitter Closing and IRM 13.2.5.5.2, Internal Submitter Closing;
- Communicate changes resulting from the project with affected stakeholders, if warranted;
- Verify each recommendation in the "Recommendations" window is documented in Phoenix;
- Complete the Closing Summary in Phoenix. The purpose of the summary is to provide a concise description of the systemic problem, if any, and outcomes.
The project closing summary will contain:
• Issue – A non-technical description of the systemic problem;
• Research - Listing of the relevant IRMs, code section, etc.;
• Analysis - Key findings from research and analysis; and
• Conclusion - Advocacy efforts and outcomes.
DEDSA will notify designee of approval. Designee will perform the following within seven business days:
- Upload closing documents to Phoenix; and
- If needed, mail the closing letter.
Contact the submitter using their stated preference, phone or closing letter. Discuss the outcome of the project and document on the Phoenix task subtab and label as "Submitter Contact" .
Note:
If unsuccessful in contacting the submitter by their stated preference, then proceed with sending a closing letter. Employees are required to add their Employee Identification Number with their contact information. All closing letters must be grammatically correct and free from errors. IRM 13.6.1, Taxpayer Advocate Service Communications, the IRM 1.10.1, Office of the Commissioner of Internal Revenue Service, IRS Correspondence Manual, the Gregg Reference Manual, and theTAS Writing & Style Guide may be used for guidance.
Upload the closing letter for review to the Technical Advocacy Shared Documents SP site by all levels using current procedures provided by the manager. Send the closing letter link to the project manager in an email for approval.
Contacting associated issue submitters is not required.
Reminder:
When preparing closing documents don’t use headers or input a date or add carbon copies (CCs). A designee will verify the correct names and titles listed on letters as "CC" .
- Contact the submitter using their stated preference. Discuss the outcome of the project and document in the Phoenix task subtab and label as "Submitter Contact" . If submitter is anonymous and submission was input by TAS employee or other, document in Phoenix unable to locate or contact submitter.
- If the submitter stated an email is the preferred method of sharing the project outcome, send the submitter a copy of the "Closing Summary" in an email. Exhibit 13.2.5-4, Project Closing Email Template for Internal Submitters Only.
- Contacting associated issue submitters is not required.
Determine the stakeholders with whom the project outcomes should be shared, and the appropriate communication channels. The appropriate stakeholders will depend on the nature of the systemic issues. For example, IRM changes that affect how case advocates work TAS cases may be appropriate for a TAS Welcome Screen message. Share items that may be appropriate for LITCs with the LITC Program Office Director via email.
Examples of channels for sharing project outcomes may include:- Taxpayer Advocate Service Welcome Screen;
- TAS Intranet Home Page;
- Other TAS web pages;
- TAS Toolkit;
- TAS Forum for Managers;
- IRS.gov;
- E-news for Practitioners;
- TAP;
- Social media; or
- Consider contacting TAS Communications, Stakeholder Liaison and Online Services (CSO) for education/awareness on the IRS.gov website regarding the outcome.
Once verbally approved by the project director, the project owner will document all closing actions and then complete required actions through the Initiate Project Closure request. This generates an automatic notification to the project director.
Example:
Closing Comment: Closing summary to project director for review.
Systemic Issue Validated: Yes/NoNote:
Ensure that any recommendations requiring monitoring after project closure are added as a new task in activity subtab. Set a reminder to follow up on the expected response date. Please note in your closing comment that recommendations are to be monitored after project closure.
Once saved, the project owner will see the Project Closure Request under the status bar.The project director approves or does not approve the closure and completes the closing comments in the "Project closure Request" section. If approved, an automatic notification is generated to the DEDSA.
Example:
TAS Director Approval for Closing: Approved/Not Approved.
Closing Comment: Closing summary reviewed, approved, and forwarded to DEDSA for approval. Once saved, Phoenix updates the project status to "DEDSA Approval for Closing" .- The DEDSA reviews for approval and adds closing comments. A closing reason is provided. The Approval Date is automatically generated.
The project owner should document details in the Phoenix Recommendation window for each recommendation that is submitted to the BOD.
- The project owner will track responses to the recommendation(s).
- The project owner will need to check yes/no to Success Story for ARC/JRC, If yes, complete the Success Story/Accomplishment Summary. This info can be pulled into the annual report to Congress.
- A project may be closed but its recommendations(s) can remain open with a follow-up date to ensure the IRS has completed all required actions.
- The project owner places a follow-up date in the Recommendation window when monitoring the status of open project recommendations.
- The project owner may create a New Task on the Activities subtab setting a reminder to follow up on the recommendations expected response date.
- The project owner updates the Recommendations section when the IRS takes an action and when all actions are complete, updates the recommendation to Closed.
- There may be times when the IRS fails to implement the agreed upon changes. If that happens, discuss the situation with the project director.
- Other options include, but aren’t limited to:
• Follow-up with the process owner who agreed to the changes;
• Discuss the issue with a SME; AA; and/or TL;
• Consider discussing the issue with CNTA;
• Consider discussing the issue with DEDSA-TA, or;
• Close the project with no further action.
If there are remaining issues, discuss with the project director. Submit remaining issues on Phoenix or SP to create another advocacy vehicle.
Discuss your decision to pursue a TAS Research Request with your manager. It may be determined that a conversation with TAS Research may assist with the decision to pursue a formal request.
Make sure information is not available elsewhere (e.g., IRWeb). Learn about the topic by looking for information in a variety of sources.
Think about information that might be available at a less precise level than what you want and see if that provides enough information to meet your needs - Think about the information you have and if it is close enough to decide whether to move the project forward. For example, if you can find the number of taxpayers who file a certain form, but cannot identify how many were Married Filing Jointly who filed the form. Over 100 taxpayers file a form, but you cannot break down by the filing status. Does it matter if you cannot get the filing status? You could estimate based on overall filing status percentage for all forms, or say that only 100 people, at most, are impacted and will we spend time on this project that impacts 100 or fewer taxpayers.
Ensure your description is clear and detailed. Write your request so someone unfamiliar with your topic/premise can understand what information you want. Do not assume the person receiving the request has the same familiarity with the subject as you do. Spell out words and describe accurately what you need. Be specific. For example when requesting items for specific time periods state if you need fiscal year or calendar year data.
Note:
It should be written so someone unfamiliar with your topic/premise can understand what information you want. Spell out words and describe accurately what you mean.
Ask only for information you will need/will use - Think about how you will use the information before asking for it. (e.g., employee names would not be printed in the ARC, so do not request them).
Request is reasonable (not excessive) - Think about how much material you are asking for and how you will present the data. If you are unsure how much data you should request, ask for advice (e.g., in most instances, ten years of detailed data is probably more than you need).
Add the following format to TAS Memorandum Letterhead:
DATE:
TO: [Name]
COUNSEL
[CITY, STATE]
FROM:
[NAME]
EXECUTIVE DIRECTOR SYSTEMIC ADVOCACY
[DIVISION NAME]
SUBJECT: REQUEST FOR LEGAL OPINION
[BRIEF ONE-LINE DESCRIPTION OF ISSUE, E.G., PERIOD OF LIMITATION FOR FILING CLAIM]
Counsel opinion is requested with respect to the issue of [provide details as to the specific legal issue(s) (which may require several paragraphs and attachments)].
If you have any questions, you may call xxx-xxx-xxxx or [Systemic Advocacy Analyst name] directly in our [location] office at [telephone number and/or email address].
CC: Senior Advisor to the NTA
CC i.e., Analyst?
CC: DEDSA?
Mr./Mrs./Ms. Terry Doe, Associate Advocate
Taxpayer Advocate Service
P.O. Box 123
Stop: 1234 ABCD
City, State [zip code]
Dear Mr./Mrs./Ms. Doe:
This letter is in response to your Phoenix submission. You expressed concern regarding [restate in your words a description of the submitter’s issue]. We assigned your submission to [insert your name and contact information (e.g., John Smith, Program Analyst]. You may reach John at (xxx) xxx-xxxx.
In researching your submission [this paragraph is used to indicate the research you conducted and your conclusion as a result of the research]. [For example, We spoke with representatives of Criminal Investigation (CI), sought the interpretation of Internal Revenue Service (IRS) counsel and reviewed sample Refund Anticipation Loan (RAL) documents. The reasoning for the denial of hardship refunds. In other words, the IRS cannot refund to the taxpayer that which the taxpayer has already assigned away for consideration]. [If the result is no change, provide positive indicators of what the Taxpayer Advocate Service (TAS) is doing to make a difference in this area, if applicable]. [For example, the result would be different if. While we believe the denial of hardship refunds in these circumstances was appropriate, the National Taxpayer Advocate (NTA) has serious concerns about the Refund Anticipation Loan (RAL) industry and addressed the need for oversight of RALs in her 2005 Annual Report to Congress and continues to advocate for regulation over this industry].
Thank you for your participation in the advocacy program. We encourage you to contact our office in the future if you identify other systemic problems. If you have questions concerning this issue, you may contact the analyst listed above; write to us at 1111 Constitution Avenue, N.W., Room 3219, Washington, D.C. 20224; or email us at Systemic.Advocacy@irs.gov. Please refer to Phoenix control number XXXXX when contacting our office.
Sincerely,
/s/ Name
Deputy Executive Director Systemic Advocacy, Technical Advocacy
CC:
Note:
Designee will add appropriate contacts as a carbon copy (CC). Letters to external submitters require the signature of the Executive Director of Systemic Advocacy with a copy to the Deputy National Taxpayer Advocate (DNTA).
Note:
Closing Letters to external submitters should show employee identification number in first paragraph and below DEDSA-TA signature.
Dear (Name of Submitter),
This is in response to your Phoenix submission titled, (insert name of project from Phoenix submission).
I want to confirm our discussion on the resolution of your issue. We resolved/were unable to resolve the issue by (insert one or two sentences or bullets describing the actions taken by Systemic Advocacy and outcome of the project - how did we advocate).
Thank you for your participation in the advocacy program. We encourage you to contact our office in the future if you identify other systemic problems. Please contact me at [insert phone number] if you have any questions. Please refer to Phoenix control number (insert project number) when contacting me.
(Insert Outlook Closing Signature, which includes your name, title, phone number, TOD, time zone and ID number)
The initial delivery of the SA Measurement Program included the development of SA Quality Standards, completed and approved by the NTA in September 2005. (Revision September 2020).
The standards fall within the following categories, advocacy focus, customer focus and procedural focus with assigned attributes.
| Attribute | Description |
|---|---|
| Advocacy Focus | |
| A1 | Completed initial actions (New attribute |
| A2 | Issues were elevated appropriately (New attribute) |
| A3 | Project was fully developed (New attribute) |
| A4 | SA appropriately handled new issues not identified in initial research (New attribute) |
| A5 | Were all related issues correctly addressed? |
| A6 | Was the proposed resolution appropriate? |
| Customer Focus | |
| C1 | SA analyst provided initial contact information to the submitter during the initial contact? |
| C2 | Did SA analyst contact the submitter in a timely manner? |
| C2a | Did SA analyst make timely first contact with the submitter? |
| C2b | Did the SA analyst make all subsequent contacts to the submitter in a timely manner? |
| C3 | Was there contact and coordination with the appropriate internal and external stakeholders as required by the project? |
| Procedural Focus | |
| P1 | SA analyst appropriately documented Phoenix (New attribute) |
| P2 | Did written communications follow proper correspondence guidelines? |
| P3 | Were project completion requirements followed? |
| P3a | Project completion requirements were followed for a project closing letter. |
| P3b | Project completion requirements were followed for a project closing summary. |
| P4 | Were subsequent actions timely? |
| P4a | SA analyst took subsequent actions within 31 calendar days of a documented follow-up date. |
| P4b | SA analyst took subsequent actions within 31 calendar days of the last action when SA analysts did not set a follow-date. |
| P5 | Were the closing letter and Project Closing Summary submitted in a timely manner? |
| P5a | Closing letter submitted timely to the manager. |
| P5b | Project Closing Summary submitted timely to the manager. |