The evolution of TAS began with the establishment of the Problem Resolution Program (PRP) in 1977. The IRS designed the PRP to handle taxpayer problems that normal IRS channels could not resolve . 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.

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

The IRS Restructuring and Reform Act of 1998 (RRA 98) brought sweeping changes to TAS. Among the most significant was the development of SA and its elevation to a level equal with Case Advocacy (CA). For additional information, see IRM 13.1.1, Taxpayer Advocate Case Procedures, Taxpayer Advocate Guiding Principles of the Office of the Taxpayer Advocate.

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.

Throughout the Taxpayer Advocate Service (TAS), employees play a vital role in addressing taxpayers’ specific issues. These taxpayer problems come to TAS’s attention through several sources including offices within TAS, IRS employees, taxpayers, practitioners, and other external stakeholders.

The NTA carries out their mission through five major program objectives:

Thus, advocacy falls into five general categories:

TAS is organized around two functions:

SA 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.

The advocacy role of TAS is apparent in its mission statement: "As an independent organization with the IRS, TAS assists taxpayers in resolving tax problems with the IRS, identifies areas in which taxpayers have problems with the IRS, and makes administrative and legislative recommendations to resolve systemic tax issues."

EDSA, DEDSA-TA, DEDSA-PA

The advocacy roles and responsibilities of the EDSA‘s staff include:

ARC Program Managers
IRC § 7803(c)(2)(B)(i) requires the NTA to submit an Annual Report to Congress to identify, among other items, the ten most serious problems encountered by taxpayers and to make administrative and legislative recommendations to mitigate those problems. The ARC program managers oversee the Annual Report process and track the responses of the IRS to the recommendations contained within the ARC. IRC § 7803(c)(2)(B)(i) requires the annual Fiscal Year Objectives Report to Congress (also known as the June Report to Congress (JRC), which is also coordinated by the ARC program managers. For a detailed discussion of the ARC and JRC processes, see IRM 13.2.8, National Taxpayer Advocate’s Annual Reports to Congress (NTA ARC).

Systemic Issue Review and Evaluation Program (SIRE)
The SIRE program identifies the potential systemic issues in need of SA intervention by reviewing submissions on SAMS to identify existing and emerging issues that affect taxpayer rights, cause taxpayer burden, or are systemic in nature. SA accomplishes this by applying established review criteria, talking to submitters, thoroughly researching the submissions, determining prior TAS involvement, and recommending next steps. SAMS allows all TAS and IRS employees, as well as anyone outside of the IRS to submit a potential systemic issue to TAS. For additional information about SAMS processes see IRM 13.2.4, SAMS Administration .

Internal Management Documents/Single Point of Contact Program (IMD/SPOC)
The IMD/SPOC program supports the SA mission by ensuring TAS reviews all official communications that either designate authorities or provide guidance and instructions to IRS staff. The purpose of the review is to identify and recommend changes to procedures that unduly burden taxpayers or infringe upon taxpayer rights. TAS also uses the reviews to provide input to the clarity, accuracy, and effectiveness of IRMs, policy statements, delegations orders, letters, notices, forms, and publications. Members of the IMD/SPOC program serve on IMD-related councils, committees, groups, and task forces (e.g., IMD Council). They coordinate IRM drafting and publishing guidance with TAS IRM authors, reviewers, responsible managers, and directors. Staff also work with Taxpayer Correspondence Services (TCS) and Tax Forms and Publications (TF&P) to facilitate feedback from TAS to the authors of letters, notices, forms, and publications. See IRM 1.11.13, Internal Management Documents System, Taxpayer Advocate Service (TAS) Internal Management Document Program, for more information on the IMD/SPOC process.

Advocacy Efforts (AE)
The AE staff provide program and administrative guidance and support to the EDSA. Current areas of responsibility includethe SA Quality Review Program, the SA Operational Review Coordination, SAMS Level Three Issue Review Team, and support for the TAS Orientation Program for Leaders. AE staff coordinate the revisions to the SA IRMs or project work and organizes the submission of data from SA program leaders for the Systemic Trends Analysis Report (STAR). The staff also provides support in tracking ARC and JRC recommendations and outcomes.

Technical Advocacy Groups
There are three technical groups within SA: Processing, Examination, and Collection. The staff of these groupsconsist of analysts and technical advisors who work in a collaborative effort to resolve systemic problems. The staff advocates work on systemic issues through a variety of approaches that may include advocacy projects, IMD reviews, task forces, and the ARC. The staff may recommend changes to:
• Administrative procedures;
• Published guidance; or
• Legislation

Attorney Advisor Group (AAG)
TAS Attorney Advisors provide independent advice and guidance to the NTA and TAS on a wide variety of issues. While TAS Attorney Advisors work closely with the Office of the Division Counsel/Associate Chief Counsel (National Taxpayer Advocate Program) (CC:NTA) on various projects, the group is not part of the IRS Office of Chief Counsel and can advocate for positions differing from the Office of Chief Counsel.
TAS Attorney Advisors can help provide employees with the correct interpretation of the law. However, if a particular issue requires an official legal opinion, the Attorney Advisor will obtain a legal opinion from the IRS Office of Chief Counsel.
TAS Attorney Advisors research and draft sections of the Annual Report to Congress, the Purple Book and the Fiscal Year Objectives Report to Congress. TAS Attorney Advisors also review and comment on guidance, policies and procedures, technical manuals, IRS letters, IRS forms, and other IRS actions. TAS Attorney Advisors may assist with Case Advocacy cases, Systemic Advocacy issues and projects, and drafting or reviewing Taxpayer Assistance Orders, Operations Assistance Requests, and Taxpayer Advocate Directives. TAS Attorney Advisors engage with external stakeholders, including at conferences and meetings, by making presentations, receiving feedback, and discussing tax administration issues. TAS Attorney Advisors research and prepare responses to constituent and other inquiries from Congress and other legislative agencies (e.g., Office of Management and Budget, Government Accountability Office).

TAS Research and Analysis (RA)
TAS RA works on a diverse set of projects throughout the year, from the reports to Congress to the design and implementation of sampling plans. TAS RA conducts studies on topics of interest to the NTA and TAS. It collects, extracts, and analyzes data as well as summarizes the findings. TAS RA sometimes collaborates with other IRS research groups or contracts for studies with external researchers.

Taxpayer Advocacy Panel (TAP)
TAP is a Federal Advisory Committee to the IRS. TAP reports to the Secretary of the Treasury, the IRS Commissioner, and the NTA. The panel acts as a two-way conduit, serving as a focus group that provides feedback on IRS initiatives and programs, and as a venue for raising issues identified by taxpayers. TAP is demographically diverse, with at least one member from each state, the District of Columbia, Puerto Rico, and an International member representing taxpayers abroad.

Program Reports: SharePoint™ (SP) and Business Objects Enterprise (BOE) generate a variety of reports used to monitor inventory, work status of SAMS Issues, Advocacy Projects (APs), Immediate Interventions (IIs), Information Gathering Projects (IGPs), Collaborative Teams, Task forces, and IMD Reviews.

Program Effectiveness: SA uses SP and BOE to help identify open inventory, project progression, and issues TAS is addressing.

BOE is a data analysis system. Limited personnel create and access reports. Only a designated administrator can delete reports.

SharePoint™ is a web-based collaborative platform that serves as a document management and storage system.

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

Exhibit 13.2.1-1 , Terms and Acronyms, lists commonly used abbreviations and acronyms.

IRM 13.2.2, SAMS Administrative

IRM 13.2.3, Elevating and Reviewing Systemic Issues

IRM 13.2.4, Information Gathering Projects (IGPs)

IRM 13.2.5, Advocacy Projects (APs)

IRM 13.2.6, Immediate Interventions (II)

IRM 13.2.7, Collaborative Efforts

IRM 13.2.8, National Taxpayer’s Advocate’s Annual Reports to Congress (NTA ARC)

The EDCA support the SA mission by:

Local Taxpayer Advocates (LTAs) play a critical role in identifying and resolving systemic problems including:

Case Advocates play an important role in identifying system problems including:

Technical advisors assist SA in its mission by:

IRS ODs support the SA mission by collaborating with SA on the resolution of systemic problems within their own purview.

The Office of the Division Counsel/Associate Chief Counsel (National Taxpayer Advocate Program) (CC:NTA) provides legal advice and support to the NTA and headquarters’ employees of TAS, including SA employees. These issues include, but are not limited to:

LITCs represent individuals whose income is below a certain level and who need to resolve tax problems with the IRS. In addition, LITCs can provide information about taxpayer rights and responsibilities in different languages for individuals who speak English as a second language (ESL). LITCs offer services for free or a small fee.

LITCs assist SA with its mission by identifying systemic problems that affect low income and ESL taxpayers and working with SA to resolve those issues.

Taxpayers, practitioners, academic or research institutions, businesses, and professional groups support the SA mission by providing examples of systemic problems to SA. Through outreach, SA educates these groups on what constitutes a systemic problem and encourages them to submit these problems onto SAMS.

All IMD product reviews come into TAS to the IMD/SPOC Program Manager in SA for control and distribution of the review request throughout TAS, as appropriate, based upon subject matter expertise listings. In addition, the IMD/SPOC Program Manager provides the CCNTA an opportunity to review all chapters of IRM 13 and other IRMs primarily owned by TAS. Responsibilities include:

Clearance Reviews: The IMD clearance reviews ensure changes in IRS policy, authority, and procedures do not cause unnecessary burden on taxpayers or violate taxpayer rights. TAS must clear IMDs before the IRS publishes an IRM that may affect taxpayer rights. TAS does the vast majority of IMD reviews during the normal clearance process.

Outside of Clearance Process (OCP) Review: In resolving systemic issues, SA may identify needed IMD changes. An OCP recommendation identifies and requests a needed change to an IMD outside of the normal review process.

For more details on the IMD/SPOC program, see IRM 1.11.13, TAS Internal Management Document (IMD) Program.

Systemic Advocacy has three types of Information Gathering Projects (IGPs).

If research indicates SA must take additional advocacy action to resolve the issue, the analyst may reclassify the IGP as an Advocacy Project or Immediate Intervention.

SA creates Advocacy Projects to:

SA creates Immediate Interventions to address issues in the following circumstances:

Although Advocacy Projects are similar to Immediate Interventions, the nature of an Advocacy Project does not require immediate action by SA. Advocacy Projects may require more extensive research and negotiation with the IRS than an Immediate Intervention.

An advocacy proposal is a formalized process for notifying the BOD by memorandum of unresolved issues identified by TAS. Consider an advocacy proposal for issues creating significant taxpayer rights and burden issues when the IRS refuses to make necessary changes. The EDSA provides the memorandum to the IRS executive in charge of the process. The memorandum provides a history of the issues, agreements reached, and agreements still needed.

For a detailed discussion of when and how to issue an Advocacy Proposal, see IRM 13.2.5.4.1, Advocacy Proposals.

If the IRS still does not agree, the EDSA may ask the NTA to consider issuing a TAD.

Membership on cross-functional teams, task forces, advocacy issue teams, and councils provide SA with an opportunity to make administrative change recommendations to existing processes. These memberships can also detect and avoid potential harm to taxpayers in proposed IRS processes.

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 NTA can elevate systemic issues and make recommendations for resolution through inclusion in the ARC. In instances where resolution of a systemic issue involves a legislative change, the NTA can include a legislative recommendation in the ARC. SA plays a significant role in developing the ARC by assisting in the identification of the ten Most Serious Problems as well as assisting in identifying topics for other parts of the report.

For more information about the NTA’s Annual Reports to Congress, see IRM 13.2.8, National Taxpayer Advocate’s Annual Reports to Congress (NTA ARC).

Delegation Order 13-3 (formerly DO-250, Rev. 1), IRM 1.2.2.13.3, empowers the NTA to issue TADs. 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). IRM 13.1.4, TAS Authorities, discusses this authority.