IRS Adopts The In-Person Approach

The Internal Revenue Service (IRS) had an interesting New Year’s resolution for 2018: more in-person meetings for taxpayers who have a local IRS Revenue Officer assigned to their case.

For many taxpayers, particularly those who are unrepresented, this means that an IRS Revenue Officer will be coming to your home or place of business. The purpose of this meeting is to allow the IRS Revenue Officer to meet with the taxpayer and attempt to procure an accurate and complete Collection Information Statement (CIS).

In recent years, the IRS has seen an influx of taxpayers and their representatives attempt to “game” the system by providing half-completed CISs in an attempt to delay collection efforts. These in-person meetings are intended to circumvent those efforts. Taxpayers or their representatives will no longer be able to prolong the IRS’s collection efforts, intentionally or otherwise, by submitting half-completed CISs. This is definitely a good step forward for all of the involved parties in these cases because cases will be worked more quickly and, hopefully, taxpayer will not have to wait to secure final resolutions.

A redacted copy of one of these letters, scheduling the in-person meeting, is linked here for your review. Aside from utilizing the letter to actually schedule the date and time for the meeting, the IRS also uses the letter to advise the taxpayer of the information and documentation needed to complete the CIS and, ultimately, support a reasonable alternative to enforced collection action. A few examples of that requested information and documentation is: delinquent tax returns, bank statements, and other evidence of income or expenses.

Given the over-arching goal of the meeting, the prudent taxpayer or representative would use the time before that meeting to gather and organize the requested information and documentation. While they may not be able to gather everything that is requested, a good faith effort at gathering and organizing those documents will likely go a long way in negotiations with the IRS Revenue Officer relating to a reasonable alternative to enforced collection action.

It is important to note that the taxpayer and their representative will retain all of their traditional tools for working with the IRS, such as, Collection Due Process or Equivalent Hearings or Collection Appeal Requests. Those tools may still be helpful in negotiating a resolution to outstanding obligations. There is additional information regarding those tools here, here, and here.

Moving forward, taxpayers and representatives should be on the look-out for these letters scheduling meetings with the IRS. Use them as the opportunity that they are to work to resolve the outstanding obligations in an efficient manner.