Taxpayer Advocate Service News
  1. NTA Blog: Veterans Face Challenges in Claiming Refunds for Taxes Improperly Withheld from Disability Severance Pay

    Subscribe to the NTA’s Blog and receive updates on the latest blog posts from National Taxpayer Advocate Nina E. Olson. Additional blogs from the National Taxpayer Advocate can be found at

    With having celebrated Veteran’s Day this week, it is worth reflecting on the continuing challenges military taxpayers face.


    In December 2016, lawmakers advised that a potential 13,800 veterans had had taxes mistakenly withheld from lump-sum disability separation pay and were due refunds. The term “disability severance pay” (DSP) refers to one-time lump sum payments made to service members separated due to medical disability. DSP is paid to service members who are separated specifically because they are not fit for duty due to their disability. To be eligible, service members must be found unfit for duty; have less than 20 years of service; and have a disability rating of less than 30 percent. (“Disability rating” refers to the percentage assigned to a veteran’s medical condition to determine the amount of military benefits he or she should receive.) By law, DSP is not taxable if it is paid for combat-related injuries determined by the military service at the time of separation, or the veteran is eligible for disability compensation from the Department of Veterans Affairs (VA).

    The total cost of refunds associated with DSP was estimated to be less than $78 million. Only now, we know those projections were wildly off target. In July 2018, the Department of Defense (DoD) and the IRS announced that almost ten times that number of disabled veterans—just over 130,000—are due tax refunds under the 2016 law. The aggregate amount of taxes improperly withheld from active-duty veterans is nearly $717 billion. That number would be even higher if we were able to calculate the taxes improperly withheld from veterans who served in the reserves. In the reserve component pay system, the federal withholding for DSP is not itemized separately from the federal withholding for other payments made at time of separation. While DoD can identify that taxes were withheld from an individual reservist’s DPS and provide them notice, the agency is unable to identify the aggregate dollar amount of taxes withheld for reserve veterans.

    Prior to 2016, DoD generally treated DSP as taxable income subject to withholding, pending a disability determination by the VA, which had a separate disability evaluation process from DoD. To recoup wrongfully withheld funds, veterans could have filed an amended tax return with the IRS, but most of the thousands of veterans affected are outside of the three-year period in which they could file an amended tax return.

    Congress found that DoD had been improperly withholding taxes from DSP to disabled veterans since 1991. In December 2016, the President signed into law the Combat-Injured Veterans Tax Fairness Act of 2016, which Congress passed to correct the flaw in withholding procedures for DSP. Beginning in 2017, DoD and the VA integrated their disability evaluation systems. As a result, DoD may now rely on a veteran’s proposed VA rating to determine taxability of DSP at the time of payment. The Defense Finance and Accounting Service (DFAS) analyzed all available automated information within the military pay systems, as well as available automated historical data, to identify the affected veterans.  

    In July 2018, the IRS mailed to affected veterans over 130,000 Letters 6060-A or 6060-D that contain instructions for submitting a claim for credit or refund. Veterans can either file a claim based on their actual DSP and actual taxes withheld, or a standard refund amount, as detailed in the letter. Importantly, the letters provide information for veterans on required timeframes for filing credit or refund claims. Under the new law, veterans may claim a refund within one year from the date of the letter, even if the normal three-year period of limitations has expired. The letters also provide a special IRS toll-free number (833-558-5245, ext. 378, between 7:00 a.m. and 7:00 p.m.) for veterans to call with questions about their claims.

    However, these claims are not without problems.

    Undeliverable Letters

    Unquestionably, these refunds can make a profound and positive difference in the well-being of injured veterans. However, as of October 26, 2018, a quarter of the way through their one-year timeline for filing claims, only about 26,000 of over 130,000 veterans had made refund claims for their improperly withheld taxes—money that is legitimately due them. Of the letters the IRS mailed to veterans, about 13,000 have been returned undeliverable. Approximately 19,000 claims have been processed, and approximately 7,000 are waiting to be processed.

    At present, it is not clear what the DoD or the IRS is doing to obtain a better address for the veterans whose letters have gone undeliverable. The IRS is using the last known address on the most recent return to contact veterans. However, it’s not uncommon for veterans to have not filed returns for several years since some did not have a filing requirement or had extensions to file while deployed in combat zones, and thus, the IRS has sent letters to obsolete addresses. How can the homeless veterans be reached, for instance? The IRS could look for alternate addresses by researching various commercial databases to which it has access, including, for example, state driver’s license databases. The IRS could send to the alternate address, instead of a copy of the returned Letter 6060, generic correspondence informing the veterans about potential eligibility for DSP-related refunds and directing them to its website with directions for filing claims. In that way, the IRS would avoid disclosing personal tax information in the second letter going to a potentially incorrect address.  

    Limitation Period for Making Claims

    The good news is the IRS has advised TAS it is treating the issuance of the Letter 6060 as the starting point for the statutory period of limitations for making a refund claim. If the original Letter 6060 is returned undeliverable to the IRS, the IRS has advised the one-year refund period begins from the issuance date of a newly sent letter. In other words, the IRS will treat the original mailing as “not sent” for purposes of the limitation period. For those making claims who were not identified originally as one of the 130,000-plus eligible veterans, and who therefore never received a Letter 6060, the period of limitations will remain open indefinitely.  

    I’m very mindful that this is not a problem of the IRS’s making, and it has a lot on its plate this year, what with implementing major tax changes for the 2019 filing season. However, the IRS has decided to wait until the undeliverable letter receipts decline before annotating on the taxpayer’s account that the letter has been returned, rather than merely sent. I am concerned that the IRS’s decision to wait in updating its system to show these letters have been returned undeliverable could result in a veteran calling the IRS and being told by an assistor that he or she already received a letter and has missed (or is about to miss) the deadline for a claim, because that is what the system shows. That is, the failure to timely update the veteran’s records with a “return” notation could deprive the veteran of the extended refund claim period. The IRS should update its system and immediately search for alternate addresses for these veterans.

    Rejected Claims

    The IRS has begun rejecting some claims when IRS records indicate that the veteran never reported the lump sum DSP as taxable income. However, neither the IRS nor TAS can confirm with 100 percent certainty what occurred without third-party documents. The IRS system shows gross income and AGI, but it does not show what was reported to the IRS in the 1990s. The IRS provided a safe harbor by allowing veterans to claim a standard amount because of the difficulty veterans may have in locating old records, as well as the difficulty the IRS and DoD themselves would have in retrieving veterans’ complete financial records. I am concerned that by shifting this burden to veterans to produce records, the IRS is undermining congressional intent to do otherwise. The IRS is placing an impossible burden on this group of taxpayers:  disproving the IRS’s position as to what they did or did not do more than a quarter century ago. These outright rejections, without a complete picture, runs up against taxpayer rights to be informed, to pay no more than the correct amount of tax, and to a fair and just tax system.

    No Appeal Rights

    Additionally, the IRS letters rejecting veterans’ claims do not provide a mechanism for contesting the rejection, because none currently exists. The rejection letters also do not contain the IRS phone number dedicated for these refund claims. Absent TAS’s intervention, those veterans who received claim rejections are deprived of any recourse, violating their rights to challenge the IRS’s position and be heard, and to appeal an IRS decision in an independent forum.

    Coast Guard

    As we learned recently, the new law does not apply to Coast Guard members, who are employed by the Department of Homeland Security, not the DoD.  The legislation provides that it is the Secretary of Defense who will identify service members who were paid DSP that was improperly taxed. However, the Coast Guard does not fall under the Secretary of Defense for pay purposes. It was likely due to an unintentional oversight to exclude one branch of the Armed Forces when the law was passed. Therefore, I intend to recommend Congress extend the law to Coast Guard members to correct the mistake.  

    TAS Efforts

    Improving the IRS’s assistance to the military has been TAS’s focus in the past two years. You can read more about our concerns associated with the IRS’s inadequate assistance to the military and recommendations to improve it in my 2017 report to Congress.

    In the meantime, we are committed to filling in the gaps by delivering accurate, up-to-date information to service members and their families. TAS has developed comprehensive educational material dedicated to military tax issues for posting on We also selected the topic, Advocating for Military Clients, for TAS presentations at the IRS Nationwide Tax Forums to educate tax professionals about unique tax issues this population encounters. Additionally, TAS has initiated a widespread information campaign regarding DSP refund claims, considering the impending deadline for veterans who received a Letter 6060 to file their refund claims. TAS created detailed slides with instructions and background information for nearly 150 congressional staffers located across the country. Using the slides as a foundation, TAS briefed the staffers on how best to answer veterans’ questions on the topic. TAS also briefed multiple Low Income Taxpayer Clinic clinicians and Local Taxpayer Advocates (LTAs) on issues surrounding DSP refund claims by participating in four webinars. It was during the in-depth preparation of those briefings that TAS discovered some of the issues I have identified in this blog. Our military tax specialist will also present on the topic at the January 2019 American Bar Association, Section of Taxation Midyear Tax Meeting.

    Closing Thoughts

    It is staggering that for 25 years there were 130,000 or more disabled Service members and their families whose DSP was reduced by improper tax withholding—likely when they could have used the funds most. Almost inconceivably, many of these Service members have died before Congress passed the legislation that would mandate a tax refund to them.

    These are the very people we cannot forget. And Veterans Day is a fitting holiday, not only to remember and celebrate our veterans for their willingness to serve and make sacrifices on behalf of the rest of us, but also to bring attention to the challenges facing these taxpayers. There are many moving parts to this refund program and I am hoping this blog will help bring all those parts together to ensure that all veterans entitled to their refunds actually get them. That is the very least we can do to show our gratitude.

    The views expressed in this blog are solely those of the National Taxpayer Advocate. The National Taxpayer Advocate is appointed by the Secretary of the Treasury and reports to the Commissioner of Internal Revenue. However, the National Taxpayer Advocate presents an independent taxpayer perspective that does not necessarily reflect the position of the IRS, the Treasury Department, or the Office of Management and Budget.

  2. Success Story: Taxpayer Advocate Service’s persistence reduces tax debt

    Every year, the Taxpayer Advocate Service (TAS) helps thousands of people with tax problems. This story is only one of many examples of how TAS helps resolve taxpayer’s tax issues. All personal details are removed to protect the taxpayer’s privacy.

    Sometimes taxpayers contact TAS for help with one issue and, in resolving that issue, multiple issues arise – some of them quite complex. In this case, a taxpayer contacted TAS for help with a payment agreement for overdue taxes spanning more than twenty tax years. In researching the taxpayer’s accounts, the case advocate noted some expired collection statutes. The IRS generally has ten years from the date the return is filed and assessed to collect the taxes.

    The advocate sent a referral to the IRS and asked it to correct the statutes on the taxpayer’s accounts, but the IRS’s initial response was that the taxpayer’s statutes were correct. The advocate consulted with a technical advisor, found additional IRS guidance and sent another request to the IRS asking it to make the necessary account corrections. The advocate’s persistence, advocacy, and thorough research resulted in the taxpayer paying no more than the correct amount of tax. In this case, the taxpayer’s debt was rightfully reduced by more than $100,000.00.

    When working with the Taxpayer Advocate Service, each individual or business taxpayer is assigned to an advocate who listens to the problem and helps the taxpayer understand what needs to be done to resolve their tax issue. TAS advocates will do everything they can to help taxpayers and work with them every step of the way. Occasionally TAS features stories of taxpayers and advocates who work together to resolve complex tax issues. Read more TAS success stories.

    Learn more about whether TAS can help you:TAS eligibility.

  3. NTA Blog: When Evaluating its Pilot Program on the Participation of Counsel and Compliance in Conferences, Appeals Should be Transparent and Should Consider Both Objective and Subjective Data

    Subscribe to the NTA’s Blog and receive updates on the latest blog posts from National Taxpayer Advocate Nina E. Olson. Additional blogs from the National Taxpayer Advocate can be found at

    Over the years, I have expressed significant concern with the continuing erosion of taxpayers’ right to appeal an IRS decision in an independent forum. (IRC § 7803(a)(3)). Of late, one of the major challenges to this right and to the independence of Appeals has been Appeals’ express desire to include IRS Counsel and Compliance in conferences regardless of whether taxpayers consent to this expanded participation. I have blogged about this before and also raised the subject in my Fiscal Year 2019 Objectives Report to Congress. Nevertheless, the issue continues to exist and I believe it is important to revisit the concerns and suggest a transparent, data-driven way forward.

    In October 2016, Appeals revised its Internal Revenue Manual (IRM) guidance to encourage the inclusion of Counsel and Compliance in conferences (IRM Beyond my own misgivings, this emphasis generated substantial uneasiness within the tax practitioner community. Among other things, stakeholders expressed fears that the inclusion of Counsel and Compliance in Appeals conferences would fundamentally change the nature of those conferences and would jeopardize Appeals’ independence, both real and perceived. I also warned that adding Counsel and Compliance to Appeals conferences could generate additional costs for the government and taxpayers in the form of fewer case resolutions, additional litigation, and reduced long-term compliance.

    Subsequently, Appeals clarified that, although Counsel and Compliance would be involved in Appeals proceedings, their participation would end prior to the commencement of settlement negotiations. While this limitation is welcome, if Counsel and Compliance are still allowed an additional opportunity to argue for their positions, the dynamic of the Appeals conference is changed, and the ATE’s role as independent decisionmaker is jeopardized. Occasionally, some taxpayers might appreciate the increased involvement of Counsel and Compliance in the Appeals process as a means of expediting a negotiated settlement. That being said, this expanded participation should be consensual, not the result of a mandate by Appeals. Such unilaterally imposed, “take it or leave it” procedures are wholly inconsistent with the cooperative, bilateral environment best suited for voluntary case resolution.

    In its response to my recommendations in the 2017 Annual Report to Congress, Appeals emphasized that this expanded participation was, at least for the moment, being implemented only as part of “a limited pilot focused on a very small population of large, complex cases involving well-represented taxpayers” (pages 153-159). However, the problems against which both I and tax practitioners previously warned have arisen even in cases involving the small group of taxpayers best situated to deal with problems flowing from the attendance of Counsel and Compliance at their Appeals conferences.

    At a recent Tax Executives Institute conference, practitioners reported a number of troubling developments occurring as part of the pilot (2018 TNT 188-6). These include cases that go on too long because Appeals Team Case Leaders (ATCLs) fail to rein in Compliance, phone calls between ATCLs and Compliance from which taxpayers and their representatives are excluded, Compliance being allowed to supplement its position late in the game, and generally inconsistent application of ground rules. So far, the closest Appeals has come to addressing these serious concerns is to suggest that practitioners mention them in a related survey that “would hopefully be available by next spring” (2018 TNT 188-6). While it makes sense to do an orderly, representative survey of program participants, by failing to address these allegations directly and promptly, Appeals could be viewed as finding nothing wrong with the behavior complained of.  A more immediate investigation by Appeals is warranted, along with a commitment to additional training for the program’s participants, particularly in the area of ex parte communication.

    In order to preserve its own legitimacy and to protect taxpayer rights, Appeals must ensure that the pilot program is evaluated based on qualitative and quantitative measures and that the results, including Appeals’ own evaluation, are published in a fully transparent fashion. For example, a decision regarding whether to continue, expand, or abandon the participation of Counsel and Compliance in Appeals conferences should only be reached after considering the impact such participation has on the cycle time and the frequency and favorability of settlements in cases within the pilot, as compared with comparable cases in the general Appeals inventory. This data, along with the observations of participants and the analysis of Appeals, should then be made available to stakeholders for review and comment.

    At that point, working collaboratively with stakeholders and the National Taxpayer Advocate, Appeals will be in a position to decide where things should go from here. Appeals has the opportunity to enhance its own credibility and effectiveness as an administrative dispute resolution vehicle by proceeding in a fair, transparent, and collaborative manner. I urge Appeals to embrace this opportunity as it moves forward in evaluating the pilot program.

    The views expressed in this blog are solely those of the National Taxpayer Advocate. The National Taxpayer Advocate is appointed by the Secretary of the Treasury and reports to the Commissioner of Internal Revenue. However, the National Taxpayer Advocate presents an independent taxpayer perspective that does not necessarily reflect the position of the IRS, the Treasury Department, or the Office of Management and Budget.

  4. The 2018 Nationwide Tax Forums a Success for TAS

    Each year, the IRS sponsors the Nationwide Tax Forums, a three-day series of tax education and networking conferences for tax professionals in cities around the country.

    The 2018 Tax Forums featured the latest information from the IRS, news about tax law changes, a chance to meet with software vendors, and the opportunity to attend seminars presented by IRS and TAS employees in addition to members of professional associations.
    TAS offered three seminars, oversaw the Case Resolution Program and held two focus groups. The TAS seminars received positive comments from many of the participants. TAS seminar topics included:

    • Advocating in Liability Cases using IRS Innocent Spouse Provisions – Innocent Spouse MLI
      This presentation defined the legal terms used in the code and the types of relief available under the statute. The course reviewed Form 8857, Request for Innocent Spouse Relief, and discussed how to effectively explain to the IRS why they should grant the requested form of relief.

    • Advocating for your Client in Cases Involving Charitable Contribution Deduction Issues
      This presentation started with a general overview of the rules for charitable contribution deductions under section 170 of the Internal Revenue Code, a recurring topic discussed in the Most Litigated Issues section of the National Taxpayer Advocate’s Annual Report to Congress. Recent court cases were examined and advocacy tips for practitioners were provided.

    • Advocating for Your Uniformed Client – Military Tax Issues
      This presentation provided a general overview of the military tax issues, especially for those serving overseas and issues involving combat zone pay and exclusions, and refund claims under the Combat-Veterans Tax Fairness Act of 2016. If you missed this seminar, you can still take this seminar for credit; visit the IRS Tax Forum Online.

    Case Resolution Program

    This year, practitioners brought their toughest unresolved IRS case (one case per tax business) to the Case Resolution Program (CRP). IRS and TAS representatives with specialized expertise were available to meet with the practitioners one-on-one to discuss their case. Nearly 900 cases were worked at the tax forums with a 99% resolution rate.

    Please make plans to join us next year and bring your toughest case. Start looking for information in the spring. Remember, you must present a signed, original or copy of your Power of Attorney to schedule the appointment.

    Focus Groups

    TAS hosted two focus groups this year at all five locations and practitioners were eager to give TAS their views. The topics were IRS Service Channels and Experiences with the IRS Audit Process. The National Taxpayer Advocate is very interested in practitioners’ opinions on these topics and how TAS can advocate for taxpayers in these areas.

    Look for your opportunity to sign up for the 2019 Tax Forums this spring. We look forward to seeing you.

  5. NTA Blog: Now is the Perfect Time for the IRS to Make Improvements to the Individual Taxpayer Identification Number Program

    Subscribe to the NTA’s Blog and receive updates on the latest blog posts from National Taxpayer Advocate Nina E. Olson. Additional blogs from the National Taxpayer Advocate can be found at

    For years, I’ve been writing about the problems with how the IRS runs the Individual Taxpayer Identification Number (ITIN) program.  ITINs are required for persons who are not eligible for a Social Security number (SSN), but who have a tax filing requirement.  My 2017 Annual Report to Congress includes a discussion of how the IRS fails to analyze the unique characteristics of the ITIN population and understand their needs.  Most recently, I wrote in my Fiscal Year 2019 Objectives Report to Congress about how the IRS is missing the opportunity to make needed changes to the ITIN program that are feasible due to the potential effects of recent legislation.  I want to turn to this topic again today and provide some numbers that further support the trends and related arguments I made.  I’ll conclude with a heartbreaking story from a recent TAS case that demonstrates how the IRS’s ITIN policies are harming taxpayers.  (The taxpayer has given us consent to share this story.)

    In recent years, Congress passed two laws that have had a significant impact on ITIN taxpayers or will so in the following years.  In 2015, Congress passed the Protecting Americans from Tax Hikes (PATH) Act of 2015, which made many changes to the ITIN program, laying out rules for how to apply, when an ITIN must be issued to receive certain tax credits, when an ITIN expires, and when the IRS can use its math error authority to deny credits related to an ITIN.  Under the PATH Act, an applicant must apply by providing original identification documents or copies certified by the issuing agency, or have those documents certified by a Certifying Acceptance Agent (CAA) or a Taxpayer Assistance Center (TAC).

    In 2017, Congress passed the Tax Cuts and Jobs Act (TCJA), which changes certain tax benefits for tax years 2018 through 2025 that were previously available to ITIN holders. The TCJA requires a qualifying child to have an SSN issued by the tax return due date to claim the Child Tax Credit (CTC), including the refundable portion known as the Additional Child Tax Credit (ACTC).  Before, a timely-issued ITIN was sufficient for claiming the credit.  The new law also eliminated the dependency exemption for these years, which could previously be claimed for ITIN holders residing in the United States, Canada, or Mexico, and meeting other requirements.  

    These changes result in a major opportunity for the IRS to make needed adjustments to the ITIN program.  First, there is less of a concern about ITINs being used for purposes other than tax administration because under the PATH Act, they now expire after three consecutive tax years of non-use.  Thus, the IRS could relax its strict requirement that taxpayers must apply for a new ITIN with a paper tax return during the filing season to show a tax administration purpose for the ITIN.  The IRS already allows renewal applicants to apply prior to the filing season, presuming they have a tax administration purpose for the ITIN based on past use.  The IRS could extend this flexibility to all ITIN applicants and could even require alternative proof of tax administration purpose, such as pay stubs or bank statements demonstrating the taxpayer will have a filing requirement. 

    Second, the removal of the refundable ACTC for children with ITINs sharply limits the potential for fraudulent refunds associated with ITINs.  Already, the number of taxpayers claiming the ACTC for children with only ITINs has been plummeting in recent years – from almost 900,000 in processing year (PY) 2014 to a projected 300,000 for PY 2018.  (A processing year runs from January through December and excludes two or three cycles at the beginning of the calendar year when data is not posted to the master file.)  TAS predicts during PY 2019, when the ACTC can only be claimed for children with ITINs on prior year returns, the IRS will only receive about 15,000 ACTC claims for ITIN children. 

    At present, the IRS requires dependent applicants to mail original identification documents to the IRS unless they use a CAA or TAC.  However, CAAs can only certify birth certificates and passports for dependents, and TACs can only certify birth certificates, passports, and national I.D. cards for dependents.  Thus, with a reduced risk of claiming fraudulent refundable credits for ITIN children, the IRS should reconsider its limitations on CAAs and TACs that prevent them from certifying all identification documents for ITIN dependent applicants.  This would allow more ITIN applicants to avoid sending their original identification documents to the IRS, risking loss of documents (more on that later).

    Finally, ITIN applications are projected to plummet because of the TCJA’s restriction on the CTC and ACTC, and its elimination of the dependency exemption during tax years 2018-2025, which should cause the IRS to reconsider the mail service it uses to return original identification documents.  During the last four processing years, an average of 1.3 million ITINs per year were used to claim the dependency exemption.  This year, we’ve already seen a sizable decrease in new ITIN applications, and as of the first week of October, the IRS had received only about 570,000 new ITIN applications, almost 8 percent lower than the same time last year and about 40 percent lower than the IRS had projected.  At the same time, due to the increased number of ITINs expiring that have been used in recent years, we’ve seen an increase in renewal applications – approximately 545,000 received as of the first week of October, compared to only 304,000 received at the same point last year.  However, in the coming years, we expect the number of renewal applications to level off as the IRS completes the deactivation of all ITINs issued prior to 2013 as required by the PATH Act.  

    Even though returning all original identification documents by expedited mail may be prohibitively expensive with the current number of ITIN applications and renewals (the IRS previously stated this could cost millions of dollars), the IRS could at least return all original identification documents by mail with some type of tracking service.  This way, the IRS could see where each document was and at what stage of processing.  The ITIN application could ask for the taxpayer’s email or cell phone number so that the taxpayer could consent to having the IRS email or text the tracking number to the taxpayer.  The IRS could also use text or email to prompt the taxpayer to contact the IRS about a change in address, which would reduce the risk of lost documents. 

    TAS recently received a case from a parent who is a citizen of another country and working in the United States on a visa.  The taxpayer applied for and was an issued an ITIN for his young child; yet, the taxpayer never received back from the IRS the child’s passport and U.S. entry visa.  This has created significant problems for the family.  First, the child now has no legal identification.  Second, even though the family can apply for a new passport for the child, the parents and child would have to travel to their home country to receive a U.S. entry visa.  Third, under the family’s terms of admission into the United States, they must leave the country and return in early 2019.  The family had planned to take a short vacation to a contiguous country, but now, without an entry visa for their child, they must return to their home country during this time and go through the entire visa application and interview process again.  Including the airfare, accommodations, and living expenses, the family estimates the trip will cost approximately $7,000, which is money they do not have.  This case shows how the IRS’s continued procedure of mailing original ID documents with no tracking system significantly harms taxpayers.  

    Issues with the ITIN process continue to harm taxpayers and impact taxpayer rights, particularly the right to quality serviceand the right to a fair and just tax system.  Now is the perfect time for the IRS to reconsider its mailing procedure as well as its policies regarding when taxpayers may apply for an ITIN and which documents may be certified by CAAs or TACs for dependents.   For further discussion of my concerns regarding ITINs see my FY 2019 Objectives Report to Congress

    The views expressed in this blog are solely those of the National Taxpayer Advocate. The National Taxpayer Advocate is appointed by the Secretary of the Treasury and reports to the Commissioner of Internal Revenue. However, the National Taxpayer Advocate presents an independent taxpayer perspective that does not necessarily reflect the position of the IRS, the Treasury Department, or the Office of Management and Budget.