The IRS issued a news release on May 19 to provide an official update regarding operational status. Most notably, the IRS has reopened the Practitioner Priority Service (PPS) Line. This line is staffed by IRS customer service representatives working from home who can answer questions regarding domestic accounts. Due to the technological limitations caused by teleworking, the services that PPS representatives can provide are extremely limited. Callers to the PPS line can request 147C letters, which verify an entity’s address or EIN, and 385C letters, which confirm whether an entity made an S election. The IRS will send these letters via fax. Callers can also request first time abatement (FTA) waiver over the phone. IRS customer service representatives are not able to generate any notices or letters for mailing.
IRS representatives staffing the PPS line can also provide callers with tax account transcripts and tax return transcripts. In an effort to combat identity fraud, the IRS stopped faxing taxpayer transcripts many months ago. Following the procedural change, tax transcript requests can only be mailed directly to the taxpayer or sent to a taxpayer representative’s secure e-services mailbox. With the current limitations, the IRS employees are not mailing transcripts to taxpayers. IRS employees are only able to send transcripts to a caller’s secure e-services mailbox. Please note that for all of these services, the IRS still requires authorization. If valid authorization is not already on file, a validly executed Form 8821 or Form 2848 can be faxed to the IRS customer service representatives e-fax number that they will provide while on the call. At this time the IRS Central Authorization File (CAF) remains closed and is not processing authorizations to be placed on file.
The IRS has also reopened its International Line for limited functions. Although originally it was believed that IRS started to assign EIN numbers to entities organized outside the United States, we have confirmed today that the IRS is unable to issue Federal Entity Identification Number (FEIN) to entities organized outside of the United States. Currently, there is no workaround this issue. Representatives responding to calls on the international phone line are able to generate tax account and tax return transcripts.
The IRS Office of Chief Counsel and the IRS Office of Appeals are still working to resolve cases that commenced prior to COVID-19 shut downs. IRS Examiners may also continue to request information from taxpayers under examination. However, because these employees are working remotely, conferences may be held over the telephone or by videoconference. Taxpayers should work with their assigned IRS officer to find a means to electronically submit correspondence.
Most other IRS services remain inoperative. Taxpayers can still receive some guidance from automated phone lines, but the IRS continues to advise taxpayers with questions about tax law, refund status, tax payments and Economic Impact Payments. Taxpayers needing forms and publications should visit irs.gov to download the forms. Moreover, the IRS recommends that taxpayers e-file tax returns and forms when possible. Although IRS service centers are receiving and storing mail, many IRS employees are not on site to process paper tax returns. Because of this there are delays in processing any of the paper submissions, including quick refund claims – Forms 4466.
In a May 19, 2020 message to employees, the IRS Commissioner announced his anticipation of bringing back more employees starting June 1 to work in its Texas, Utah, and Kentucky centers. The National Treasury Employees Union more specifically stated that there will be a mandatory call back of 11,000 employees. Previously, the IRS asked for 11,000 employees to voluntarily return to the office, but the volunteer numbers fell short of the IRS goal. If the mandatory callback actually occurs on June 1, it will most likely be essential non-portable work related to the current filing season.
If you have any questions about IRS operations or have a specific question about IRS procedure, please contact the drafters of this alert or any member of the Tax Controversy Team.