For today’s post, I will summarize the status on IRS examination and collection operations as of August 2020. Back on March 25, 2020, the IRS launched “The People First Initiative” program which postponed Installment Agreements and Offers-in-Compromise payments and suspended IRS enforcement actions. Many of the actions and postponements were announced to last only until July 15, 2020, but tax practitioners like me still experience IRS service delays and unavailability in August 2020.
After reading all the latest IRS updates and notices, I have put together a working list of what IRS operations are running and what operations are still down broken down by sections.
Here is the list as of August 2020:
IRS Field Collections
- The moratorium on IRS Liens is still ongoing despite the July 15 deadline. Current rumor is the moratorium ends on August 31.
- The moratorium on IRS Levies is still ongoing despite the July 15 deadline. Current rumor is the moratorium ends on August 31.
- The moratorium on IRS Passport Certifications is still ongoing despite the July 15 deadline. No news on when moratorium ends.
- On the same vein, passport decertification requests processing are delayed due to limited staffing and resources.
- IRS Audits have begun already back on July 15.
- Revenue Officers are now pursuing high-income non-filers. A high-income non-filer is one who makes over $100,000.
- Private debt collection activities are suspended beyond July 15.
IRS Return and Payments Processing
- Paper returns are taking much longer to process.
- Installment Agreement payments are now resumed.
- Offer-in-Compromise payments are now resumed.
IRS Programs and Systems
- As of April 2020, a new Streamlined Installment Agreement is available for taxpayers owing $100,000 – $250,000 and whose accounts are assigned with the Automated Collection System (“ACS”). The Installment Agreement must be paid over 72 months and requires no collection information statement. However, a lien will be filed!
- Taxpayers who are assigned with Revenue Officers still have to owe less than $100,000 for a Streamlined Installment Agreement.
- Installment Agreement approvals are still delayed.
- Practitioner Priority Service is open but with long delays on the phone.
- Centralized Authorization File Unit are taking at least 15 business days to process Form 2848 Power of Attorney.
Because of the moratoriums on liens and levies, taxpayers will get a break from any enforcement action by the IRS. However, those making above $100,000 should file and pay their taxes as soon as possible. In addition, the postponed and suspended IRS activities do not toll the 10-year collection period but the IRS will still try to preserve its collection rights by contacting taxpayers who are close to the 10-year period.
Once the IRS is up and running in the fall, taxpayers should expect to receive notices. If the IRS contacts you or someone you know, please feel free to contact me for help at either (404) 747-7073, or by email at [email protected].
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