IRS Management: IRS Faces Challenges as it Restructures the Office of the
Taxpayer Advocate (Letter Report, 07/15/1999, GAO/GGD-99-124).

Taxpayers testified before Congress in 1997 about the difficulties they
had had in trying to get help from the Internal Reserve Service (IRS) in
resolving ongoing problems. Specifically, concerns were raised about
IRS' Office of the National Taxpayer Advocate, which was set up to help
taxpayers who (1) have been unable to resolve their problems elsewhere
in IRS or (2) are suffering significant hardships. GAO identified
shortcomings in the Office and in the Problem Resolution Program that
could affect how efficiently and effectively services are provided to
taxpayers. For example, the Office lacked control over resources for its
Problem Resolution Program. It did not know how many employees were
working in the program or the costs associated with that staffing. Some
staff said that they lacked the necessary training, and limited
advancement opportunities make it difficult for the Office to hire and
retain qualified employees. Also, demands on the Office to resolve
individual taxpayer problems left little time for staff to identify the
causes of recurring taxpayer problems and recommend solutions. The
Office is in the midst of improving its operations. Many of these
changes, such as restructuring Office operations and creating career
paths for local advocates, are outgrowths of the requirements of the IRS
Restructuring and Reform Act of 1998. Other changes, such as developing
position descriptions for Problems Resolution Program caseworkers, are
the result of Office initiatives. It is too soon to tell, however, how
effective these changes will be in overcoming the problems GAO cited.
Two areas in which changes are being considered are advocacy and
performance measures. But changes in both areas require better
information systems than are now available.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  GGD-99-124
     TITLE:  IRS Management: IRS Faces Challenges as it Restructures
	     the Office of the Taxpayer Advocate
      DATE:  07/15/1999
   SUBJECT:  Taxpayers
	     Human resources utilization
	     Internal controls
	     Customer service
	     Performance measures
	     Federal agency reorganization
IDENTIFIER:  IRS Problem Resolution Program
	     IRS Advocacy Project Tracking System
	     IRS Problem Resolution Office Management Information
	     System
	     IRS Taxpayer Advocate Management Information System
	     IRS Customer Feedback System
	     IRS PRP Case Identification and Tracking System

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    United States General Accounting Office GAO               Report
    to the Chairman, Committee on Ways and Means, House of
    Representatives July 1999         IRS MANAGEMENT IRS Faces
    Challenges as it Restructures the Office of the Taxpayer Advocate
    GAO/GGD-99-124 United States General Accounting Office GAO
    Washington, D.C.  20548 General Government Division B-279035 July
    15, 1999 The Honorable Bill Archer Chairman, Committee on Ways and
    Means House of Representatives Dear Mr. Chairman: Witnesses at the
    Senate Finance Committee hearings in September 1997 included
    taxpayers who described difficulties they had experienced in
    trying to get help from the Internal Revenue Service (IRS) in
    resolving ongoing problems. As a result of their experiences,
    specific concerns were raised about the operations of IRS' Office
    of the National Taxpayer Advocate (Advocate's Office) that had
    been created, in part, to help such taxpayers. You requested that
    we review operations of the Advocate's Office and the Problem
    Resolution Program (PRP) administered by that office. In response
    to that request, this report discusses (1) challenges the National
    Taxpayer Advocate (Advocate) faces in managing program resources,
    (2) the potential effects of workload fluctuations on program
    operations, (3) information available to help the Advocate
    determine the causes of taxpayer problems and prevent their
    recurrence, and (4) the adequacy of performance measures IRS uses
    to gauge program effectiveness. As part of an agencywide effort to
    align IRS processes with taxpayer needs, IRS is designing a new
    structure for the Advocate's Office. With the permission of your
    office, we briefed the Advocate and the IRS team responsible for
    redesigning the Advocate's Office several times during the course
    of our review. During these briefings, we discussed various issues
    that we had identified during our review and provided feedback on
    proposed redesigns of the structure and operations of the
    Advocate's Office. Additionally, we testified on the results of
    our work at hearings held by your Oversight Subcommittee on
    February 10, 1999.1 We identified various management and
    operational challenges facing IRS, Results in Brief    the
    Advocate's Office, and PRP. How these challenges are addressed
    could affect how efficiently and effectively taxpayers are helped
    by PRP. 1IRS Management: Challenges Facing the National Taxpayer
    Advocate (GAO/T-GGD-99-28, Feb. 10, 1999). Page 1
    GAO/GGD-99-124 Taxpayer Advocate Office B-279035 First, the
    Advocate's Office faced resource management challenges because it
    lacked direct control over most PRP resources. Specifically, (1)
    the Advocate's Office did not know how many staff were working in
    PRP or the costs associated with that staffing; (2) the Advocate's
    Office had to rely on resources provided by IRS' operating
    functions, such as Customer Service, Collections, and Examination;
    (3) some Advocate Office and PRP staff reported that they lacked
    training that Advocate Office officials considered necessary; and
    (4) the Advocate's Office faced obstacles, such as limited
    advancement opportunities, in acquiring and keeping qualified
    staff. Planned changes to the Advocate's Office and PRP, such as
    placing PRP resources under the control of the Advocate's Office,
    could mitigate some of these issues. However, it is too early to
    evaluate the impact of these changes. Second, IRS faces challenges
    as it restructures the Advocate's Office to better handle
    variations in PRP's workload. According to Advocate Office
    officials, in the past, because PRP operations depended on IRS
    functional units for resources, any fluctuations in PRP's workload
    were handled by adjusting the number of functional staff assigned
    to work PRP cases. However, the Advocate's Office is moving away
    from a structure that relies on other IRS units for staffing,
    which may make it more difficult for the Advocate's Office to
    handle workload fluctuations, especially workload increases. The
    Advocate told us that he was committed to helping any taxpayer who
    contacts the office. While it is understandable why the Advocate's
    Office might not want to turn away anyone seeking help, accepting
    cases that could be handled elsewhere in IRS could overburden PRP.
    Third, the demands on the Advocate's Office to resolve individual
    taxpayer problems has left little time for staff to spend
    identifying the causes of recurring taxpayer problems and
    recommending solutions. Also, limitations in the kind of
    information available provided little assurance that the time
    being spent was being used most effectively. These efforts on
    recurring problems, called advocacy, are key to the success of the
    Advocate's Office because the improvements they generate can
    reduce the number of taxpayers who ultimately require help from
    PRP. Finally, IRS lacked adequate measures of the effectiveness of
    the Advocate's Office and PRP. Measures of effectiveness should
    cover the full range of Advocate Office operations so they can be
    used to improve program performance, increase accountability, and
    support decisionmaking. The set of measures used by the Advocate's
    Office during our review focused on descriptive program events
    instead of program Page 2
    GAO/GGD-99-124 Taxpayer Advocate Office B-279035 outcomes; did not
    provide complete data; or were not based on consistent data
    collection. The Advocate's Office is identifying and implementing
    changes aimed at addressing some of the issues identified in this
    report; however, it is too soon to tell the efficacy of these
    efforts. Additionally, some of the changes might require more
    extensive efforts than are currently planned to alleviate the
    problem cited. IRS founded PRP in 1976 to provide an independent
    means of helping Background    taxpayers solve problems that they
    encountered in dealing with IRS. Initially, PRP units were
    established in IRS district offices. In 1979, IRS expanded PRP to
    its service centers and created the position of Taxpayer Ombudsman
    to head PRP. The Ombudsman was appointed by and reported to the
    Commissioner of Internal Revenue. Congress has since renamed the
    Ombudsman the "National Taxpayer Advocate" and shifted appointment
    authority to the Secretary of the Treasury.2 However, the Advocate
    continues to report to the Commissioner. To promote the
    independence of the Advocate, Congress required that the
    individual not be an IRS employee for 2 years preceding his or her
    appointment and that the individual not accept a position
    elsewhere in IRS for 5 years following his or her tenure as the
    Advocate.3 The current Advocate was appointed in August 1998, in
    accordance with these provisions. Additionally, to enhance
    independence, the Advocate is required to submit annual reports
    directly to Congress on the objectives and activities of the
    Advocate's Office. These reports are to be developed by the
    Advocate's Office and are to be submitted directly to Congress
    without any prior review or comment from the Commissioner of
    Internal Revenue, the Secretary of the Treasury, or any other
    officer or employee of the Department of the Treasury. The
    Advocate manages an organization (i.e., the Advocate's Office)
    that has advocates in each of IRS' 4 regions, 33 districts, 30
    former districts,4 and 10 service centers and in the Executive
    Office for Service Center Operations (EOSCO)5 in Cincinnati, OH,
    and the Office of the Assistant 2IRS Restructuring and Reform Act
    of 1998, P.L. 105-206 (July 22, 1998). 3Service as an officer or
    employee of the Advocate's Office is not taken into account for
    purposes of the 2-year and 5-year rules. 4In fiscal year 1996, IRS
    consolidated its field operations and reduced the number of
    districts from 63 to 33. The former 30 districts continue to have
    staff and operations, including a local advocate's office. 5Before
    the establishment of EOSCO, the regions were responsible for
    service centers within their geographic boundaries.
    Organizationally, EOSCO is on a par with the regions. Page 3
    GAO/GGD-99-124 Taxpayer Advocate Office B-279035 Commissioner
    (International) in Washington, D.C.6 The regional and EOSCO
    advocates are responsible for providing program oversight and
    support to advocates in the district, former district, and service
    center offices (hereafter referred to as "local advocates"), who
    manage PRP operations at the local level. This program oversight
    and support is to include reviewing PRP casework, ensuring the
    training of PRP staff and staff in the Advocate's Office, dealing
    with sensitive individual cases, pursuing advocacy initiatives,
    and handling potential hardship cases. Formerly, the regional and
    local advocates were selected by and reported to the director of
    the regional office, district office, or service center where they
    worked. However, the IRS Restructuring and Reform Act of 1998
    changed that relationship. Now, regional advocates are to be
    selected by and report to the National Taxpayer Advocate, and
    local advocates are to be selected by and report to regional
    advocates. At the time we completed our review in May 1999, most
    PRP casework was being done by district office and service center
    staff, called caseworkers, who were employees of IRS' operating
    functions, such as Customer Service, Collection, and Examination.
    In addition, each function doing PRP work had a coordinator to
    ensure that all PRP cases within the function were assigned to
    caseworkers and placed under PRP control and to provide
    coordination between the function and the local advocates. PRP
    caseworkers and coordinators were funded by the operating
    functions, not the Advocate's Office. Also, each district office
    and service center had its own PRP structure, which reflected
    differences in office size and composition and in the way PRP
    caseworkers were managed. In the past, PRP caseworkers were
    generally assigned to functional units and reported to functional
    managers. In recent years, some local offices centralized their
    PRP casework in PRP units staffed by functional employees who
    reported directly to the local advocate. The goals of the
    Advocate's Office are consistent with IRS' mission of providing
    quality service to taxpayers by helping them meet their tax
    responsibilities and by applying the tax laws fairly. The
    Advocate's goals are to 6The Office of International District
    Operations serves essentially as a district office for taxpayers
    living outside the United States. Page 4
    GAO/GGD-99-124 Taxpayer Advocate Office B-279035 *  assist
    taxpayers who cannot get their problems resolved through normal
    IRS channels or those who are suffering significant hardships. For
    example, local advocate offices can expedite tax refunds or stop
    enforcement actions for taxpayers experiencing significant
    hardships. This assistance is provided through PRP. During fiscal
    year 1998, PRP closed more than 300,000 cases, of which about 10
    percent involved potential hardships; *  determine the causes of
    taxpayer problems so that systemic causes can be identified and
    corrected and to propose legislative changes that might help
    alleviate taxpayer problems. IRS commonly refers to this process
    as advocacy; and *  represent taxpayers' interests in the
    formulation of IRS policies and procedures. Our objectives were to
    (1) identify challenges the Advocate faces in Objectives, Scope,
    managing program resources, (2) identify potential effects of
    workload and Methodology         fluctuations on program
    operations, (3) determine what information was available for
    advocacy efforts, and (4) assess the adequacy of performance
    measures IRS used to gauge program effectiveness. For all of our
    objectives, we interviewed Advocate Office officials at IRS'
    National Office, all 4 IRS regional offices, and EOSCO, and we
    interviewed local advocates, PRP coordinators, and caseworkers in
    17 of IRS' 73 local offices-including 9 district offices, 4 former
    district offices, and 4 service centers. For the first objective,
    we also surveyed Advocate Office and PRP staff, including PRP
    caseworkers, at IRS locations where Advocate's Office and PRP work
    was being done. Additionally, for the third and fourth objectives,
    we reviewed program documents on the Advocate's Office and PRP,
    including guidance on advocacy efforts, and program management
    information, including goals and measures for the program. For a
    more detailed account of our scope and methodology, including IRS
    offices visited and limitations of our surveys, see appendix I. We
    did our work from December 1997 to May 1999 in accordance with
    generally accepted government auditing standards. We requested
    comments on a draft of this report from the Commissioner of
    Internal Revenue. His written comments are discussed near the end
    of this report and are reprinted in appendix VII. Page 5
    GAO/GGD-99-124 Taxpayer Advocate Office B-279035 We identified
    several resource management issues within the Advocate's Resource
    Management Office and PRP that could affect how efficiently and
    effectively taxpayers Issues Present                  are helped
    by PRP. Specifically, (1) the Advocate's Office did not know how
    many staff were working in PRP or the costs associated with that
    Challenges for the              staffing; (2) the Advocate's
    Office had to rely on resources provided by Advocate
    IRS' operating functions, such as Customer Service, Collections,
    and Examination; (3) some Advocate Office and PRP staff reported
    that they lacked training that Advocate Office officials
    considered necessary; and (4) the Advocate's Office faced
    obstacles, such as limited advancement opportunities, in acquiring
    and keeping qualified staff. Addressing such issues presented a
    particular challenge to the Advocate's Office because it has not
    had direct control over most PRP resources. IRS has begun to
    address some of the resource management issues we identified.
    Other changes to the Advocate's Office and PRP are being
    considered in conjunction with a major effort that IRS has begun
    to substantively revise its organizational structure. However, it
    is too soon to tell how these changes will affect program
    operations. The Advocate's Office did not know the total number,
    time, and thus, cost The Advocate's Office           of staff
    devoted to PRP because IRS did not have a standard system to
    Lacked Information on           track functional staff doing PRP
    work.7 The absence of this basic staffing Functional PRP Staffing
    information yields an incomplete picture of program operations,
    places limitations on decisionmaking, and hinders the
    identification of matters requiring management attention. For
    example, without complete staffing information, IRS does not know
    the total cost of the program; and it cannot project the potential
    cost, for planning purposes, of any prospective changes or
    enhancements to the program. IRS' operating functions (e.g.,
    Customer Service, Collection, and Examination), which provided
    most of the staff working in PRP, had systems to track the amount
    of time employees devoted to PRP, but each function tracked time
    spent differently. The procedures varied, from having employees
    charge all time spent to resolve a case to PRP, to having them
    charge only a minimal amount of time to PRP. Because of the
    situation just described, IRS was unable to tell us how many
    functional staff were working on PRP activities and how much time
    those staff were devoting to PRP work. To get information on the
    number of functional staff, with the help of the Advocate's
    Office, we sent out 7 IRS was able to track staff in the
    Advocate's Office because these staff are funded by the Advocate's
    Office, not the functions. Page 6
    GAO/GGD-99-124 Taxpayer Advocate Office B-279035 surveys that
    solicited staffing information from all locations where Advocate
    Office and PRP work was being done. Summaries of the responses to
    our surveys are presented in appendixes II and III. Our surveys
    showed that on June 1, 1998, there were 508 staff working in the
    Advocate's Office and another 1,532 functional employees doing PRP
    casework. Selected survey results for those 1,532 PRP caseworkers
    are presented in appendix IV. As shown in that appendix, the 1,532
    PRP caseworkers included 726 district office employees and 806
    service center employees. The Advocate's Office had to rely on
    other management officials within Reliance on Functional      IRS
    to provide most of the resources-including staff, space, and
    Resources Contributed to    equipment-needed to do PRP casework.
    Because there was no direct Staffing Issues             funding
    for PRP, however, functional managers had to carve out resources
    for PRP from their operating budgets. This arrangement required
    district and service center directors to shift employees and other
    resources into or out of PRP as workload demands changed. When
    functional needs conflicted with PRP needs, there were no
    assurances that PRP needs would be met. This arrangement also
    meant that functional managers, not local advocates, determined
    which employees would do PRP casework- leaving the local advocates
    with little, if any, control over the quality of the caseworkers.
    Local advocates told us that good communication and working
    relationships with other managers within IRS was imperative to
    receive the support needed to meet PRP goals. Another result of
    the relationship just described is that local advocates were not
    responsible for preparing official performance evaluations for
    most PRP caseworkers. In that regard, our surveys showed that
    about 80 percent of the PRP caseworkers reported to and were
    evaluated by functional management. Such a situation could have
    affected the ability of caseworkers to resolve taxpayers' problems
    impartially, because those problems could involve disputes between
    the taxpayer and the function responsible for evaluating the
    caseworker. Also, this situation could have led to a perception
    that PRP was not an independent program. Independence-actual and
    apparent-is important because, among other things, it helps
    promote taxpayer confidence in PRP. Because the Advocate's Office
    did not have direct control over functional employees, PRP
    caseworkers could sometimes be pulled from PRP duties to do other
    work. For example, IRS officials said that PRP caseworkers were
    often required to help the customer service function answer
    taxpayer Page 7                                    GAO/GGD-99-124
    Taxpayer Advocate Office B-279035 telephone calls during the
    filing season. While caseworkers were helping customer service,
    they were still responsible for their PRP work. Since PRP did not
    have a direct budget, IRS officials said that it was easy for PRP
    "to fall through the cracks" in terms of getting other resources,
    such as equipment and space, for PRP work. When PRP caseworkers
    told us of their equipment needs, they generally mentioned *
    computers for word processing, *  ready access to Integrated Data
    Retrieval System (IDRS) terminals,8 *  telephone lines and voice
    mail, *  fax machines, and *  basic office supplies. Given the
    nature of PRP work, caseworker access to IDRS and the availability
    of such things as word processing equipment, voice mail, and
    telephone lines would seem essential. For example, we observed
    that caseworkers often prepared handwritten correspondence to
    taxpayers that was not as professional looking as correspondence
    prepared on word- processing equipment. According to our survey,
    some Advocate Office staff and PRP caseworkers Some Advocate
    Office and         had not received training that Advocate Office
    officials considered PRP Staff Had Not Received necessary. Our
    surveys of IRS staff who were doing Advocate Office work Training
    Considered              as of June 1, 1998, indicated the
    following: Necessary                      *  Only 35 percent of
    the staff in the Advocate's Office had attended an Advocate's
    Office training course for their current position. These positions
    included advocate, analyst, and PRP specialist. *  Fewer than half
    of the caseworkers had attended a PRP caseworker training course.
*  Almost 78 percent of the caseworkers had received PRP quality
    standards training. This training is designed to ensure that
    caseworkers are aware of the standards for acceptable PRP
    casework. Although our survey indicated that caseworkers often had
    not completed a formal PRP caseworker training course, the survey
    also indicated that about 85 percent of the caseworkers had
    received on-the-job training. While on-the-job training can be an
    effective means of teaching, it opens up the possibility of
    inconsistencies in the way the program operates. 8IDRS is the
    primary system used by IRS employees to research and adjust
    taxpayer accounts. Page 8
    GAO/GGD-99-124 Taxpayer Advocate Office B-279035 In addition to
    being trained in PRP matters, Advocate Office officials said that
    caseworkers should continue to receive training in functional
    matters. Functional training, such as training in tax law changes,
    is important because resolving taxpayer problems requires that
    caseworkers understand the tax laws affecting a particular case.
    Our surveys indicated, however, that about half of the PRP
    caseworkers had not received such functional training. Both
    Advocate Office and PRP staff who we talked to said that there was
    no established training schedule, so they did not always know what
    training was being offered. When they did hear about training, it
    was sometimes too late to sign up. Some staff said that it had
    been several years since they had received any formal PRP
    training. Both Advocate Office staff and PRP caseworkers told us
    that, in addition to the basic training needed to do PRP work,
    they would like training in other areas, especially tax law
    changes. Also, many caseworkers wanted cross- functional training
    so that they could work cases across functional lines. IRS
    officials said that cross-functional training would broaden
    caseworker skills and might lead to faster and more accurate
    service to taxpayers. Additionally, they said that by broadening
    caseworkers' skills and thus expanding the types of cases that
    they could work, cross-functional training could help the
    Advocate's Office manage workload fluctuations. Obstacles existed
    that could adversely affect the ability of the Advocate's
    Obstacles Existed to               Office to acquire and keep
    qualified staff. Those obstacles included (1) the Acquiring and
    Keeping              absence of standard position descriptions for
    PRP caseworkers that could Qualified Staff                    be
    used to help ensure that qualified staff were assigned to PRP work
    and (2) limited opportunities for advancement within the
    Advocate's Office and PRP. Obstacle to Acquiring Qualified
    There were no standard position descriptions for PRP caseworkers.
    Staff                              Instead, PRP caseworkers worked
    under the position descriptions for employees in their functional
    organizations. This situation permitted functional managers to
    fill PRP caseworker positions through a noncompetitive process.
    IRS officials said that management usually asked for volunteers to
    work in PRP; if no volunteers came forward, management usually
    assigned staff to PRP, based on reverse seniority (i.e., staff
    with the least seniority would be assigned to PRP if not enough
    volunteers were forthcoming).9 Without competition, less qualified
    staff could be assigned 9 Many of the caseworkers we talked with
    enjoyed working in PRP more than doing functional work. In the
    customer service function, PRP work was viewed as being especially
    desirable because most customer service staff spent their time
    answering telephone calls from IRS' toll-free lines and PRP work
    offered a respite from the telephone activity. However, some
    caseworkers said that they did not Page 9
    GAO/GGD-99-124 Taxpayer Advocate Office B-279035 to PRP. IRS
    officials said that if there were standard PRP caseworker position
    descriptions, staff from the operating functions would have to
    meet a set of qualifications and then compete for caseworker
    positions. As in any organization, when staff compete for a
    position, management is afforded an opportunity to select from
    among the best-qualified staff for the duties prescribed for that
    position. Obstacle to Keeping Staff    IRS officials said that the
    grade structure and size of the Advocate's Office and PRP limited
    opportunities for staff to advance within these organizations.
    There were gaps in the Advocate's Office and PRP grade
    structure.10 These gaps meant that, at some point, staff who
    wanted to advance their careers would have to leave the Advocate's
    Office or PRP to get a promotion elsewhere in IRS-generally in an
    operating function. In addition, the small size of the Advocate's
    Office and PRP (in terms of number of positions) meant that there
    were fewer numbers of promotions available than in the larger
    operating functions. Advocate Office and PRP staff who we talked
    to had mixed views on whether they would have promotion
    opportunities within the functions. Because the Advocate's Office
    was "off line" from the operating functions, many of the Advocate
    Office staff said that they would not have the background
    necessary to compete for a promotion in an operating function.
    Instead, they said that the only way for them to leave the
    Advocate's Office would be through a lateral transfer. Many
    caseworkers told us, however, that the knowledge and skills they
    acquired in PRP could potentially enhance their opportunities in
    their functional organizations. IRS has taken some actions and has
    others planned that are related to the IRS Has Begun to Address
    resource management issues previously discussed; however, it is
    too soon the Resource Management      to tell if these actions
    will fully address these issues. Issues Facing the Advocate's
    Office            Many of the actions were being developed as part
    of IRS' effort to redesign the agency and are scheduled to be
    completed by the end of fiscal year 1999. IRS is planning
    substantive changes to the agency's organizational structure and
    work processes. Among other things, those plans would eliminate or
    substantially modify IRS' existing organization and establish want
    to continue working in PRP because increased workloads and higher
    program visibility made the job too stressful. 10In some local
    advocate offices, for example, the associate advocate was a
    General Schedule (GS)-12 and the advocate was a GS-14. There was
    no GS-13 position in the office. Because of that gap, an associate
    advocate would have to go elsewhere in IRS to get a promotion to
    GS-13. Page 10
    GAO/GGD-99-124 Taxpayer Advocate Office B-279035 organizational
    units serving particular groups of taxpayers, such as wage earners
    and small businesses. In commenting on a draft of this report, IRS
    said that, beginning in October 1999, it will have the ability to
    track Advocate Office resources accurately. Resource management
    changes include realigning the PRP staffing so that all
    caseworkers report to local advocates, not functional management.
    This should give the Advocate's Office more control over PRP
    resources. In October 1998, IRS announced that those caseworkers
    who were already reporting to local advocates-about 20 percent-
    would officially be part of the Advocate's Office. In addition, at
    the time we completed our audit work, IRS was developing an
    implementation plan to have the remaining 80 percent of the
    caseworker positions assigned to local advocate offices during
    fiscal year 1999. To complement the shift to direct reporting of
    caseworkers and further strengthen the independence of the
    Advocate's Office, IRS established for fiscal year 1999 a
    separate, centralized financial structure for managing all
    Advocate Office resources. This structure covers the resources
    allocated to the Advocate's Office and includes PRP caseworkers
    who have been transferred from the functions to the Advocate's
    Office. Having a separate, centralized structure gives the
    Advocate's Office control over its resource and should prevent
    Advocate Office funds from being redirected to other IRS programs.
    As of May 1999, IRS was also developing and updating the training
    for Advocate Office staff and PRP caseworkers. The training is to
    reflect the new operating structure and procedures for the
    Advocate's Office as part of the agencywide redesign effort.
    Training needs for all Advocate Office and PRP staff are to be
    identified by the end of fiscal year 1999. Other actions could
    make it easier for the Advocate's Office and PRP to acquire and
    keep qualified staff. In that regard, IRS has developed position
    descriptions for all staff working in the Advocate's Office and
    PRP. The Advocate said that all positions within the Advocate's
    Office and PRP will be filled competitively using the new position
    description. This includes having all existing Advocate Office and
    PRP staff reapply for their current positions. IRS has reevaluated
    the PRP caseworker duties and, in many cases, the new caseworker
    positions are higher-graded than the current caseworker positions.
    According to the Advocate, the competition for the positions
    should help ensure that the best staff are selected for the
    Advocate's Office and PRP. Page 11
    GAO/GGD-99-124 Taxpayer Advocate Office B-279035 Additionally, in
    an effort to attract and keep qualified staff, the IRS
    Restructuring and Reform Act of 1998 required that the Advocate
    develop a career path for local advocates who choose to make a
    career in the Advocate's Office. In response to this requirement,
    the Advocate, at the time we completed our audit work, had a plan
    that would not only provide a career path within the Advocate's
    Office and PRP, but would also enable Advocate Office and PRP
    staff to compete for jobs in the operating functions. According to
    local advocates, dealing with workload fluctuations- Handling
    Workload       especially increased workloads-poses a challenge
    for them as Advocate's Fluctuations Poses a    Office and PRP
    operations are restructured. (See app. V for factors that have
    increased and could increase PRP's workload.) IRS uses "cases
    Challenge as the        closed" as its indicator of PRP workload.
    As figure 1 shows, the number of Advocate's Office       PRP cases
    closed in fiscal years 1993 through 1998 varied from year to
    Restructures            year. Figure 1: PRP Cases Closed (Fiscal
    Years 19931998) Cases in thousands 500 400 300 200 Cases closed
    100 0       1993         1994    1995       1996       1997
    1998 Fiscal year Note: PRP cases that were opened and closed on
    the same day are not included in the totals because they were not
    included in the IRS database from which this information was
    obtained. Source: IRS Office of the National Taxpayer Advocate.
    Historically, because PRP was staffed by the functions, the
    Advocate's Office relied on the functions to provide additional
    staff to cover workload increases. However, as discussed
    previously, this reporting structure could Page 12
    GAO/GGD-99-124 Taxpayer Advocate Office B-279035 have led to the
    perception that PRP lacked independence. In an attempt to
    alleviate this possible perception, and as part of the
    restructuring effort, all caseworkers are to be placed in the
    Advocate's Office. Workload increases may make it necessary for
    the Advocate's Office to Workload Increases Could         decide
    which cases to address with PRP resources. PRP was designed to
    Affect PRP Services              help taxpayers who were unable to
    get their problems resolved elsewhere in IRS. However, the
    Advocate told us that he was committed to helping any taxpayer who
    contacts the office. We understand why the Advocate's Office might
    not want to turn away any taxpayers seeking help. However, if the
    Advocate's Office accepts cases that could be handled elsewhere in
    IRS, PRP could be overburdened, potentially reducing its ability
    to help taxpayers who have nowhere else to go to resolve their
    problems. As one local advocate said, "if everything is a
    priority, then nothing is a priority." Overburdening PRP could
    also result in less staff time available for the Advocate's Office
    to devote to advocacy. We discuss that issue in more detail in the
    next section. In its plan to redesign the Advocate's Office, IRS
    has acknowledged the need to handle workload fluctuations. In the
    event of workload increases, the Advocate's Office needs to be
    able to either decrease the number of cases entering the program,
    increase the number of staff working on cases, or some combination
    of both. The Advocate said that for workload increases, IRS plans
    to detail additional staff from the functions, as necessary. In
    his written comments on a draft of this report, the Commissioner
    of Internal Revenue stated that IRS had recently modified the PRP
    criteria to create a "taxpayer focused balance between cases
    handled by the Taxpayer Advocate and other functions." We did not
    have time to evaluate the potential impact that the modified
    criteria might have on PRP workload. (See app. V for a list of the
    PRP criteria.) Through advocacy, the Advocate's Office is to
    identify the underlying Better Information               causes of
    recurring taxpayer problems and recommend changes in the tax Could
    Help Ensure the law or in IRS' systems or procedures. Advocacy is
    key to the success of the Advocate's Office because the
    improvements it generates could reduce the Best Use of Resources
    number of taxpayers who ultimately require help from PRP. However,
    the for Advocacy Efforts             advocates we talked with
    indicated that the demands on Advocate Office staff and PRP
    caseworkers to resolve individual taxpayers' problems left little
    time to spend on advocacy. In addition, because of limitations in
    the kind of information available to and compiled by the
    Advocate's Office, there was little assurance that the time being
    spent on advocacy was being Page 13
    GAO/GGD-99-124 Taxpayer Advocate Office B-279035 used most
    effectively. As of May 1999, the Advocate was considering various
    ideas for improving the advocacy process. As discussed more fully
    below, the advocacy process involves all levels of Time Spent
    Working on       the Advocate's Office, from the Advocate to local
    caseworkers. Individual Taxpayer         Nevertheless, most of the
    advocates we talked with said that the need to Problems Has
    Limited the    work on individual taxpayer problems limited the
    amount of time that Time Available for          advocate staff and
    PRP caseworkers could spend on advocacy. In that regard, our
    surveys indicated that, as of June 1, 1998, advocates and their
    Advocacy                    staffs were spending about 60 percent
    of their time on problems of individual taxpayers11 and about 10
    percent of their time on advocacy.12 PRP caseworkers were spending
    almost all of their PRP time on problems of individual taxpayers.
    The advocacy process within the Advocate's Office involves all
    levels of The Advocacy Process        the organization, from the
    Advocate to local caseworkers. The Advocate's Office is
    responsible for (1) assisting, supporting, and guiding advocacy
    efforts at all levels; (2) identifying issues with nationwide
    implications and assigning responsibility for conducting research
    on these issues to regional advocates; and (3) compiling
    information on the status of ongoing and completed advocacy
    projects. Advocacy projects are intended to develop
    recommendations for improving IRS processes and procedures that
    can be forwarded to the function responsible for the processes or
    procedures. Advocate staff are to monitor the implementation of
    the recommendation and, in instances in which no action is taken
    by the function, the Advocate can compel the function to implement
    the recommendation by issuing a Taxpayer Advocate Directive. The
    Advocate was delegated this authority in March 1998, and on
    December 7, 1998, he issued the first directive requiring that IRS
    operations abate penalties on some "innocent spouse" cases.13 As
    of April 1999, there had been no other directives issued. Each
    region and EOSCO has an advocacy council comprised of Advocate
    Office staff and functional executives and staff. These councils
    are 11Advocates and their staffs generally deal with sensitive
    cases, such as congressional inquiries, and cases in which a
    taxpayer has applied for relief due to hardship. 12The remainder
    of their time was spent on other types of Advocate Office work,
    such as program management and support. 13To qualify for innocent
    spouse relief, a person must have filed a joint return with an
    understatement of taxes owed; the understatement must result from
    erroneous items of the spouse; and the person applying for
    innocent spouse relief must not have known about the errors caused
    by the other spouse. Prior to the IRS Restructuring and Reform Act
    of 1998, the understatement must have exceeded the greater of 500
    dollars or a specified percentage of the innocent spouse's
    adjusted gross income for the most recent year. Page 14
    GAO/GGD-99-124 Taxpayer Advocate Office B-279035 responsible for
    promoting advocacy and serve as clearinghouses for advocacy
    efforts by evaluating the merits of recommendations proposed at
    the regional and local office levels and by assigning projects to
    local advocates for further research. In evaluating the merits of
    local and regional advocacy recommendations, the councils are to
    either (1) endorse a recommendation and forward it to the National
    Office, (2) decide that a recommendation has merit but that more
    work needs to be done to support it, or (3) decide that the
    recommendation does not have merit. The councils are also
    responsible for providing guidance to local offices on advocacy
    projects and for ensuring that local offices receive feedback on
    advocacy projects. Local advocates receive ideas for advocacy
    efforts from a variety of sources, such as PRP's case inventory
    system, PRP caseworkers, functional staff, and tax practitioners.
    In some cases, immediate action can be taken by local managers to
    improve local procedures and prevent local administrative
    problems. In other cases, the idea may be studied at the local
    office and recommendations for improvement can be forwarded to the
    responsible advocacy council for agencywide consideration.
    Advocacy recommendations also come from the Equity Task Force,
    which was chartered to make recommendations to the Advocate. The
    task force is comprised of a cross-section of IRS functional
    executives, functional staff, and Advocate Office staff.
    Recommendations from the task force are designed to further the
    interests of fairness in tax administration. We understand the
    need for the Advocate's Office to give priority to Inadequate
    Information           individual taxpayer problems (i.e.,
    casework) over advocacy when there is Available to Ensure the
    not enough time to do both. If the PRP workload were to increase,
    it could Most Effective Use of Time       become even more
    difficult for the Advocate's Office to find time to spend Spent on
    Advocacy                on advocacy. The Advocate's Office must,
    therefore, make the best possible use of the time available for
    advocacy. However, at the time of our review, the Advocate's
    Office did not have the kind of information needed to (1) make
    sound decisions on which projects to undertake and (2) protect
    against wasteful duplication of effort. Information On Which
    Projects    The Advocate's Office did not systematically gather
    the information To Work Was Limited              needed to
    identify and prioritize advocacy projects. For the most part,
    advocacy projects were identified by analyzing the codes used to
    categorize taxpayer problems for the Advocate's case inventory
    system. However, IRS officials said that analyzing these codes was
    not the best means of identifying advocacy projects because the
    codes do not provide enough information on the nature of the
    problems. Page 15                                  GAO/GGD-99-124
    Taxpayer Advocate Office B-279035 For example, one code indicates
    that the problem involved a lost or stolen refund. However, there
    is no way to tell from the code why the case ended up in PRP.
    There are normal procedures for taxpayers and IRS to follow in
    getting a lost or stolen refund replaced. The fact that such a
    case ended up in PRP does not indicate whether there was some
    procedural failure that resulted in IRS' inability to produce a
    replacement refund for the taxpayer. This level of detail may be
    available on individual cases-in the case history section-however,
    there is no way to search the Advocate's case inventory system for
    this information. As a result, the inventory system can only
    describe the frequency of taxpayer problems; it cannot describe
    why the problem ended up in PRP. In the absence of such
    information, the Advocate's Office does not know which advocacy
    efforts have the greatest potential to resolve recurring taxpayer
    problems. Comprehensive Information on       We found that the
    Advocate's Office did not have a comprehensive source Advocacy
    Projects Not Available of information on all proposed, ongoing,
    and completed advocacy projects. Additionally, we found that field
    staff did not always have access to information on advocacy
    projects. Because advocacy projects can be started at any level in
    the Advocate's Office, it is important that everyone have access
    to comprehensive information on advocacy projects. Among other
    things, such information should help enhance coordination and
    prevent unnecessary duplication of effort. Information on advocacy
    efforts is available from the (1) the Advocacy Project Tracking
    System, (2) an inventory of legislative recommendations, and (3)
    the Commissioner's Tracking System. None of these three sources
    provides a comprehensive listing of advocacy projects. The
    Advocacy Project Tracking System is a document maintained by the
    Advocate's Office that includes completed and ongoing advocacy
    projects from IRS' four regional offices and EOSCO. The document
    is presented as a matrix with information on each project, such as
    the project title, a short description of the project, the project
    contact points, and the status of the project's recommendations.
    The matrix was last updated as of September 30, 1998, and there
    were 39 projects listed. The matrix does not, however, contain any
    information on what projects were ongoing or planned at the local
    offices. The inventory of legislative recommendations aimed at
    changing the current tax law is a document that presents potential
    legislative changes recommended by each region and EOSCO. The list
    is also presented in matrix format with information on each
    recommendation, such as whether there is an advocacy project
    related to the issue, what the proposed action Page 16
    GAO/GGD-99-124 Taxpayer Advocate Office B-279035 is, and the
    status of the recommendation. The list is tracked by fiscal year,
    and those recommendations that the Advocate endorsed are to be
    included in the Advocate's Report to Congress. As of April 1999,
    there were seven legislative recommendations on the list. This
    listing, however, is limited to proposed changes to legislation
    and does not contain any information on ongoing, proposed, or
    completed advocacy projects. The Commissioner's Tracking System is
    a document that is to contain information on all advocacy
    memorandums that were sent to functional management. Advocacy
    memorandums are to be sent from the Advocate to a National Office
    function when the function resists or does not respond to a
    recommendation that the Advocate feels will alleviate harm to
    taxpayers or decrease taxpayer burden. Advocacy memorandums are to
    be sent only after other inquiries or attempts to resolve the
    issue have proved unsuccessful. The function is asked to respond
    in writing to the advocacy memorandum. If the functional area does
    not provide a satisfactory reason for not implementing a
    recommendation, the Advocate can compel the function to implement
    the recommendation by issuing a Taxpayer Advocate Directive, as
    explained previously. Information on the Commissioner's Tracking
    System and information from the directives are to be included in
    the Advocate's Annual Report to Congress. As of April 1999, the
    Advocate had written 12 advocacy memorandums. This document only
    contains those advocacy recommendations that were not willingly
    implemented by the functions and is not a complete source of
    advocacy projects. The lack of a comprehensive source of
    information on all advocacy projects increases the risk of
    unnecessary duplication of effort. In that regard, staff at
    several locations said that regional and local offices are often
    studying similar problems. For example, an IRS regional official
    said that two of IRS' regions were studying projects on several
    similar issues, including (1) the application of taxpayer
    overpayment credits and (2) waiving the 10 percent additional tax
    penalty on withdrawals from Individual Retirement Accounts in
    hardship cases. The official also said that there was even less
    awareness of ongoing efforts at the district office and service
    center levels than at the regional level described above. A more
    comprehensive source of information on advocacy projects might
    also help provide staff with better feedback on project results.
    Although each IRS region and EOSCO has an advocacy council that is
    responsible for providing feedback to district and service center
    staffs, the local advocates and council members with whom we
    talked said that there was no formal mechanism for providing
    feedback. In particular, council Page 17
    GAO/GGD-99-124 Taxpayer Advocate Office B-279035 members said that
    staff who had worked on projects were not receiving status reports
    or even an acknowledgment that recommendations from their projects
    were being considered for possible implementation, even though the
    councils were responsible for providing this information. In one
    district, for example, the local advocate said that he had
    forwarded the same advocacy recommendations to the regional
    council over the course of several years, but had not received
    feedback concerning what actions, if any, were taken on these
    recommendations. In October 1998, the Advocate established a team
    to develop Proposed Changes for      recommendations to strengthen
    advocacy within IRS. The team's goal was Strengthening Advocacy
    to develop and recommend a national advocacy plan, and the team
    made Efforts Are Under         several recommendations to the
    Advocate for initiating and coordinating Consideration
    advocacy projects. For example, in its February 1999 report to the
    Advocate, the team recommended that a national advocacy database
    be developed to provide a single source of information on ongoing
    advocacy projects. The national database would contain information
    on all advocacy efforts, including those at the national,
    regional, and local levels. In addition, the database would be
    accessible to all local advocates. As part of the effort to
    redesign the Advocate's Office, the Advocate said that he plans to
    adopt the recommendations from the team. Also, the redesign plan
    calls for establishing separate casework and advocacy units, each
    with its own dedicated staff, thus reducing the possibility that
    advocacy will suffer in times of high PRP caseloads. IRS lacked
    adequate measures of the effectiveness of the Advocate's Office
    The Advocate's Office     and PRP. The set of measures used by the
    Advocate's Office during our Lacked Adequate           review (1)
    provided descriptive information about program activities, such as
    the average amount of time it takes to close a PRP case, rather
    than Measures of               information needed to assess
    effectiveness; (2) did not provide complete Effectiveness
    data; or (3) were not based on consistent data collection. IRS has
    efforts under way to improve program measures. Those efforts, at
    least as they relate to the Advocate's Office, may be hampered by
    existing information systems. While it is necessary for an
    organization to measure program activities, such as average case
    processing time, the more important and more difficult task is to
    develop measures of effectiveness that focus on the impact of an
    agency's programs on its customers. Measures of effectiveness are
    important because they provide data to improve program
    performance, increase accountability, and support decisionmaking.
    We found that the Advocate's Office had measures to gauge certain
    aspects of PRP's performance, but that these measures could not
    fully assess PRP's Page 18
    GAO/GGD-99-124 Taxpayer Advocate Office B-279035 effectiveness.
    For example, the Advocate's Office did not have a method for
    measuring customer satisfaction, and there was no mechanism for
    determining the effectiveness of advocacy efforts-both of these
    measures would help the Advocate understand how effective the
    program is in helping taxpayers. During our review, the Advocate's
    Office was using the following four Existing PRP Measures Are
    measures to gauge PRP's performance: (1) average processing time
    to Inadequate                   close PRP cases, (2) currency of
    PRP case inventory, (3) quality of casework, and (4) case
    identification rate. Although those measures provided some useful
    information, they did not provide all of the information needed to
    assess PRP's effectiveness. (See app. VI for more information on
    these measures.) The first two measures, average processing time
    and currency of case inventory, provide descriptive information
    about program activities. Although these measures are useful for
    some program management decisions, such as the number of staff
    needed at a specific office, they do not provide information on
    PRP's effectiveness. The third measure is designed to determine
    the quality of PRP casework. Although this measure provides some
    data on program effectiveness, it provides no information on
    customer satisfaction. In commenting on a draft of this report,
    IRS said that it is developing ways to measure PRP customer
    satisfaction and that it plans to test and refine the measure
    beginning in October 1999. By helping taxpayers resolve problems
    that were not resolved elsewhere in IRS, the Advocate's Office
    plays a pivotal role in delivering customer service to the
    taxpayers. Customer satisfaction data from taxpayers who contacted
    PRP could provide the Advocate's Office with information on how
    taxpayers feel about the service they received and whether
    taxpayers consider their problems solved. Without this
    information, the Advocate's Office is not in the best position to
    improve program operations to better satisfy taxpayer needs. The
    fourth measure, PRP case identification, attempts to determine if
    service center employees are properly identifying potential PRP
    cases from incoming correspondence. This measure is an important
    tool to help the Advocate's Office know whether PRP actually
    serves those taxpayers who qualify for help from the program.
    However, the measure provides an incomplete picture because it is
    designed for use only at service centers. There is no similar
    measure to determine how well district offices and toll- free
    telephone call sites are identifying and referring potential PRP
    cases. Page 19                                  GAO/GGD-99-124
    Taxpayer Advocate Office B-279035 Also, a recent review of the PRP
    case identification measure by IRS' Office of Internal Audit
    disclosed, among other things, that inconsistent data collection
    could affect the integrity and reliability of the measure's
    results. For example, Internal Audit found that the test was not
    always performed the required number of times per month at each
    service center and that the mail sample was not based on the
    service center's incoming mail population. Additionally, when
    Internal Audit performed a parallel PRP case identification
    sample-in accordance with national standards-its rates for some
    service centers were significantly lower-in one case, over 55
    percentage points lower--than rates reported by the service
    center. In addition to the shortcomings of these four measures,
    IRS lacked a method for determining the effectiveness of its
    advocacy efforts. Advocacy is a major responsibility of the
    Advocate's Office and is aimed at ultimately reducing the number
    of taxpayers needing help from PRP. Without information on the
    effectiveness of these efforts, the Advocate's Office does not
    know, for example, which efforts provide the greatest benefit to
    taxpayers. The Advocate is working to improve Advocate Office and
    PRP measures of Current Information          effectiveness. In
    January 1999, as part of its efforts to redesign the Systems May
    Limit IRS'       Advocate's Office, IRS established a task force
    to determine what Ability to Develop Needed    measures are needed
    to assess program effectiveness. Specifically, the Measures
    group is tasked to research, identify, and develop corporate level
    measures for Advocate Office program results, customer
    satisfaction, and employee satisfaction. Their ability to develop
    needed measures of effectiveness, however, may be hampered by
    existing information systems. The Taxpayer Advocate Management
    Information System is comprised of the Problem Resolution Office
    Management Information System (PROMIS), the Customer Feedback
    System, and the PRP Case Identification and Tracking System. These
    systems do not provide the Advocate's Office with the data it
    needs to assess the effectiveness of PRP operations. PROMIS is a
    computerized inventory control and report system that includes
    information from individual PRP cases, such as the taxpayer's
    name, address, and Social Security number. PROMIS generates
    reports on cumulative descriptive program data, such as the number
    of cases worked in PRP and how quickly cases are closed. Although
    the system also captures data on the types of problems taxpayers
    are experiencing-such as the "lost or stolen refund" example
    mentioned earlier-there is no mechanism to search for other data
    that might help advocacy efforts by pointing to agencywide
    weaknesses. For instance, there is no way to determine if cases
    were caused by problems with a particular IRS system Page 20
    GAO/GGD-99-124 Taxpayer Advocate Office B-279035 because the cases
    are coded only by type of tax problem. In a case history section,
    PROMIS captures information on the nature of the taxpayer's
    problem and what actions were taken to help the taxpayer. However,
    there is no mechanism to search multiple cases for trend data from
    the history section. The Customer Feedback System is designed to
    capture taxpayers' compliments and complaints about IRS employees.
    The system depends on taxpayers to take the initiative to
    voluntarily comment about the treatment they received from an IRS
    employee and on IRS managers to complete the customer feedback
    form. The voluntary nature of the system means that the data are
    not statistically representative of program participation, and
    fluctuations in the data cannot be attributed to changes in
    program operations. In addition, comments captured on the system
    could relate to any IRS function, not just PRP, and therefore, are
    of limited use in assessing PRP's effectiveness. The PRP Case
    Identification and Tracking System is used to capture information
    on the PRP case identification measure discussed earlier. As such,
    it has the same limitations as that measure-it only has
    information on cases coming into IRS through correspondence at the
    service centers. Because this system contains no information on
    cases coming in through district offices and call sites, it
    provides incomplete data on whether taxpayers who qualify for PRP
    assistance are being properly identified and referred to PRP. In
    addition to the problems with the Taxpayer Advocate Management
    Information System, we mentioned earlier that the Advocate's
    Office lacked a system to track resources dedicated to the
    program. Because PRP was implemented through IRS' functions, the
    Advocate's Office had no system to track the resources devoted to
    PRP. Without this basic program information, the Advocate's Office
    had no means to determine what it invested in the program. The
    Advocate's Office can provide a valuable service by helping (1)
    Conclusions    taxpayers who have been unable to resolve their
    problems elsewhere in IRS and (2) taxpayers who are suffering
    significant hardships. We have identified challenges, obstacles,
    and deficiencies in Advocate Office and PRP operations that could
    affect how efficiently and effectively services are provided to
    taxpayers. The Advocate's Office is in the midst of identifying
    and implementing changes designed to improve its operations. Many
    of the changes, such as restructuring Advocate Office operations
    and Page 21                                  GAO/GGD-99-124
    Taxpayer Advocate Office B-279035 creating career paths for local
    advocates, are due to requirements of the IRS Restructuring and
    Reform Act of 1998; other changes, such as developing position
    descriptions for PRP caseworkers, are the result of Advocate
    Office initiatives. However, it is too soon to tell how effective
    these changes will be in addressing the challenges cited in this
    report. Two areas in which changes are being considered are
    advocacy and performance measures. However, changes in both areas
    require the development of better information systems than are
    currently available. For example, without a system or systems that
    provide (1) information needed to identify and prioritize advocacy
    projects and (2) comprehensive information on all proposed,
    ongoing, and completed advocacy projects, IRS has no assurance
    that the Advocate's Office is most effectively using the resources
    available for advocacy. Similarly, without a system or systems
    that provide better data than are now available in the Taxpayer
    Advocate Management Information System, IRS' ability to develop
    appropriate measures of PRP effectiveness may be hampered. To
    better ensure that the Advocate's Office effectively uses the
    resources Recommendations to              available for advocacy
    and thus enhances its ability to prevent the the Commissioner of
    recurrence of taxpayer problems and ultimately reduce the number
    of taxpayers who need help from PRP, we recommend that the
    Internal Revenue                Commissioner of Internal Revenue
    direct appropriate officials to define the requirements for and to
    develop a system that captures the kind of information needed to
    identify and prioritize potential advocacy projects and provide
    feedback to staff on ongoing and completed projects. To better
    manage PRP resources and improve operations, we recommend that the
    Commissioner of Internal Revenue direct appropriate officials to
    design management information systems that can support outcome-
    oriented performance measures. The Commissioner of Internal
    Revenue commented on a draft of this Agency Comments and report by
    letter dated July 7, 1999, in which he generally agreed with our
    Our Evaluation                  findings and concurred with our
    recommendations. (See app. VII for a copy of the letter.) We
    modified the report to ensure technical correctness and include
    updated information where appropriate. We are sending copies of
    this report to Representative Charles B. Rangel, Ranking Minority
    Member, House Committee on Ways and Means; Representative Amo
    Houghton, Chairman, and Representative William J. Coyne, Ranking
    Minority Member, Subcommittee on Oversight, House Committee on
    Ways and Means; and Senator William V. Roth, Jr., Page 22
    GAO/GGD-99-124 Taxpayer Advocate Office B-279035 Chairman, and
    Senator Daniel P. Moynihan, Ranking Minority Member, Senate
    Committee on Finance. We are also sending copies to The Honorable
    Lawrence H. Summers, Secretary of the Treasury; The Honorable
    Charles O. Rossotti, Commissioner of Internal Revenue; The
    Honorable Jacob J. Lew, Director, Office of Management and Budget;
    and other interested parties. Copies of this report will be made
    available to others upon request. If you have any questions
    regarding this letter, please contact me or David Attianese at
    (202) 512-9110. Key contributors to this assignment were Kelsey
    Bright, Isidro Gomez, and Susan Malone. Sincerely yours, Cornelia
    M. Ashby Associate Director, Tax Policy and Administration Issues
    Page 23                                 GAO/GGD-99-124 Taxpayer
    Advocate Office Contents 1 Letter 26 Appendix I
    Offices Visited
    26 Detailed Scope and     Program Information Reviewed
    27 Staffing Surveys
    27 Methodology 28 Appendix II            Survey Questions and
    Responses                                              28 Summary
    of Responses to the Taxpayer Advocate Staffing Survey 35 Appendix
    III           Survey Questions and Responses
    35 Summary of Responses to the Functional PRP Staffing Survey 43
    Appendix IV Selected Survey Results for PRP Caseworkers 46
    Appendix V             Broad Interpretation of PRP Criteria
    46 Factors That Have      IRS Initiatives Place Demands on Program
    Resources                          47 Legislative Requirement May
    Increase Demands on PRP                         49 Increased and
    Could Increase PRP Workload Page 24
    GAO/GGD-99-124 Taxpayer Advocate Office Contents 50 Appendix VI
    Performance Measures
    50 PRP Performance        Information Systems
    51 Measures and Information Systems 53 Appendix VII Comments From
    the Internal Revenue Service Abbreviations EOSCO        Executive
    Office for Service Center Operations GS           General Schedule
    IDRS         Integrated Data Retrieval System IRS
    Internal Revenue Service PROMIS       Problem Resolution Office
    Management Information System PRP          Problem Resolution
    Program Page 25                                    GAO/GGD-99-124
    Taxpayer Advocate Office Appendix I Detailed Scope and Methodology
    We interviewed agency officials at the Internal Revenue Service's
    (IRS) Offices Visited                          National Office,
    all 4 IRS regional offices, the Executive Office for Service
    Center Operations (EOSCO), and 17 local offices, including 9
    district offices, 4 former district offices,1 and 4 service
    centers (see table I.1 for a list of the regional and local
    offices we visited). Table I.1: Regional and Local Offices
    Regional Offices Visited
    Midstates Region (Dallas, TX) Northeast Region (New York, NY)
    Southeast Region (Atlanta, GA) Western Region (San Francisco, CA)
    District Offices Delaware-Maryland (Baltimore, MD) Central
    California (San Jose, CA) Kentucky-Tennessee (Nashville, TN)
    Manhattan (New York, NY) Northern California (Oakland, CA) North
    Texas (Dallas TX) Pacific Northwest (Seattle, WA) Pennsylvania
    (Philadelphia, PA) Virginia-West Virginia (Richmond, VA) Former
    District Offices August, ME (part of the New England District)
    Pittsburgh, PA (part of the Pennsylvania District) Portland, OR
    (part of the Pacific Northwest District) Sacramento, CA (part of
    the Northern California District) Service Centers Atlanta, GA
    Brookhaven, NY Fresno, CA Philadelphia, PA We selected the 17
    local offices on the basis of suggestions from Advocate Office
    staff; our stratification of offices to obtain a variety by size,
    type of work, and organization; and geographic convenience. At the
    National Office, we interviewed the National Taxpayer Advocate,
    his predecessor, and members of his staff. We interviewed the
    EOSCO advocate; and, at the regional and local offices, we
    interviewed the advocates and their staffs. Additionally, at the
    local offices, we interviewed Problem Resolution Program (PRP)
    coordinators and PRP caseworkers. We also attended two regional
    advocacy council meetings and discussed PRP operations with
    council members. 1 In fiscal year 1996, IRS consolidated its field
    operations and reduced the number of districts from 63 to 33. The
    former 30 districts continue to have staff and operations,
    including a local advocate's office. Page 26
    GAO/GGD-99-124 Taxpayer Advocate Office Appendix I Detailed Scope
    and Methodology We reviewed documents, including sections of the
    Internal Revenue Program Information    Manual pertaining to the
    Advocate's Office and PRP; IRS Internal Audit Reviewed
    reports on the Advocate's Office and PRP; and National Office,
    regional, district, and service center program documents. We
    reviewed program data on advocacy efforts at IRS. These data
    included Internal Revenue Manual instructions on advocacy and
    databases on ongoing and completed advocacy projects. We
    interviewed Advocate Office staff responsible for advocacy and
    local advocates and their staffs to determine how advocacy
    projects are identified and implemented. We also attended two
    Regional Advocacy Council meetings to increase our awareness of
    program operations. We did not assess IRS' effectiveness in
    implementing proposed advocacy projects because IRS Internal Audit
    had an ongoing assignment with that specific objective. We
    reviewed program management information for the Advocate's Office
    and PRP. This information included program goals and measures and
    the systems by which these data are captured. Data for the
    Advocate's Office and PRP are captured on the Taxpayer Advocate
    Management Information System, which includes three separate
    systems-the Problem Resolution Office Management Information
    System, the PRP Case Identification and Tracking System, and the
    Customer Feedback System. Through our surveys and with the help of
    the Advocate's Office, we Staffing Surveys       obtained staffing
    information from all IRS locations where Advocate Office and PRP
    work was being done. We attempted to get information for all IRS
    staff doing Advocate Office or PRP work, including PRP
    caseworkers, as of June 1, 1998. (See apps. II and III for
    summaries of the responses to our surveys.) When necessary, we
    verified responses to the staffing surveys by telephone. However,
    we did not verify that we received responses for all staff doing
    Advocate Office or PRP work. The results of our surveys were
    limited to a specific time (June 1, 1998), and responses may vary
    based on how staff interpreted our questions. Page 27
    GAO/GGD-99-124 Taxpayer Advocate Office Appendix II Summary of
    Responses to the Taxpayer Advocate Staffing Survey This appendix
    contains a summary of responses to the survey we sent to the
    National Taxpayer Advocate, the four regional advocates, the
    advocates at EOSCO and the Office of the Assistant Commissioner
    (International), and the 43 local advocates. In that survey, we
    asked for information on each person on their staffs as of June 1,
    1998, including the advocate or associate advocate, where
    appropriate. We received responses for 508 staff, including staff
    detailed to advocate offices by the operating functions. 1.
    Series?  (Provide the position series number.) Survey Questions
    and Responses Number        Percentage Seriesa        Occupationb
    of staff          of staff 301            Miscellaneous
    administration & program                             66
    13.0 303            Miscellaneous clerk & assistant
    32               6.3 313            Work unit supervising
    1              0.2 318            Secretary
    36               7.1 322            Clerk-typist
    1              0.2 326            Office automation clerical &
    assistance                              6              1.2 340
    Program management
    34               6.7 343            Management & program analysis
    201              39.6 344            Management & program clerical
    & assistance                         20               3.9 345
    Not listed
    1              0.2 356            Data transcriber
    1              0.2 392            General telecommunications
    1              0.2 503            Financial clerical & assistance
    2              0.4 511            Auditing
    1              0.2 512            Internal revenue agent
    4              0.8 526            Tax technician
    39               7.7 592            Tax examining
    35               6.9 962            Contact representative
    5              1.0 987            Tax law specialist
    1              0.2 1169           Internal revenue officer
    8              1.6 None           No response
    13               2.6 Total
    508            100.2 Note: Percentages do not equal 100 due to
    rounding. a"Series" means a number identifying a recognized
    occupation in the federal service that includes all jobs at the
    various skill levels in a particular kind of work. b"Occupation"
    means an occupational series listed in the Handbook of
    Occupational Groups and Families developed by the U.S. Office of
    Personnel Management to aid federal agencies in classifying
    positions under the Classification Act of 1949 and P.L. 92-392. 2.
    Grade?  (Provide the person's current grade level.) Page 28
    GAO/GGD-99-124 Taxpayer Advocate Office Appendix II Summary of
    Responses to the Taxpayer Advocate Staffing Survey Gradea
    Number of staff               Percentage of staff General
    Schedule-4                                                     27
    5.3 General Schedule-5
    26                           5.1 General Schedule-6
    38                           7.5 General Schedule-7
    42                           8.3 General Schedule-8
    10                           2.0 General Schedule-9
    93                          18.3 General Schedule-10
    1                           0.2 General Schedule-11
    95                          18.7 General Schedule-12
    77                          15.2 General Schedule-13
    45                           8.9 General Schedule-14
    42                           8.3 General Schedule-15
    11                           2.2 Executive Schedule-5
    1                           0.2 Total
    508                        100.2 Note: Percentages do not equal
    100 due to rounding. a"Grade" means the level of classification an
    employee has under a position classification system (i.e.,
    referring to the duties, tasks, and functions he or she performs).
    3.  Permanent or detailed?  (Indicate whether the person is
    assigned to the Taxpayer Advocate's Office on a permanent or
    detailed basis.) Assignment basis
    Number of staff               Percentage of staff Permanent
    436                          85.8 Detailed
    63                          12.4 Othera
    71 . 4 No response
    2                           0.4 Total
    508                        100.0 a"Other" includes interim and
    temporary assignments. 4.  Full-time or part-time?  (Indicate
    whether the person is a full-time or part-time IRS employee.) IRS
    employment basis                              Number of staff
    Percentage of staff Full-time
    495                          97.4 Part-time
    8                           1.6 No response
    5                           1.0 Total
    508                        100.0 Page 29
    GAO/GGD-99-124 Taxpayer Advocate Office Appendix II Summary of
    Responses to the Taxpayer Advocate Staffing Survey 5.  Percent of
    time spent on Advocate Office work?  (Estimate the percentage of
    time the person does work related to the Advocate's Office,
    including Problem Solving Day cases.  Response should be 100
    percent, unless the person also does work for another office or
    function.) Percentage of time spent on Advocate Office worka
    Number of staff            Percentage of staff 1-24
    1                         0.2 25-49
    0                         0.0 50-74
    0                         0.0 75-99
    2                         0.4 100
    505                       99.4 Total
    508                      100.0 a"Advocate Office work" includes
    work related to PRP. 6.  Years at IRS?  (Provide the number of
    years the person has worked at IRS.  Do not include other
    government experience.) Years at IRS
    Number of staff            Percentage of staff Less than 1
    2                         0.4 1-5
    7                         1.4 6-10
    68                        13.4 11-15
    123                        24.2 16-20
    108                        21.3 More than 20
    186                        36.6 No response
    14                         2.8 Total
    508                      100.1 Note: Percentages do not equal 100
    due to rounding. 7.  Years in PRP?  (Provide the number of years
    the person has done PRP work.) Years in PRP
    Number of staff            Percentage of staff Less than 1
    102                        20.1 1-5
    141                        27.8 6-10
    152                        29.9 11-15
    67                        13.2 16-20
    26                         5.1 More than 20
    4                         0.8 No response
    16                         3.1 Total
    508                      100.0 Page 30
    GAO/GGD-99-124 Taxpayer Advocate Office Appendix II Summary of
    Responses to the Taxpayer Advocate Staffing Survey 8.  Prior IRS
    function(s)?  (Check all that apply.)  (Indicate the IRS operating
    function(s) where the person worked before coming to the Taxpayer
    Advocate's Office.) Prior IRS function(s)
    Number of staff           Percentage of staff Collection
    181                           35.6 Customer Service Automated
    Collection System                                     37
    7.3 Taxpayer Service
    224                           44.1 Examination
    164                           32.3 Othera
    221                           43.5 None
    11                                2.2 No response
    6                               1.2 Note: Percentages are based on
    a total of 508 Advocate Office staff. Percentages total more than
    100, because some respondents checked more than one response to
    this question. a"Other" includes IRS functions not in the
    categories above, such as Information Systems, Resources
    Management, and Submission Processing. 9.  How acquired by the
    Advocate's Office?  (Check one.)  (Indicate how the person
    obtained a position in the Advocate's Office.) How position
    obtained                              Number of staff
    Percentage of staff Competed
    304                           59.8 Volunteered
    28                                5.5 Assigned
    64                           12.6 Detailed
    60                           11.8 Othera
    43                                8.5 No response
    9                               1.8 Total
    508                          100.0 a"Other" includes methods not
    in the categories above, such as reassignments resulting from IRS'
    reorganization and hardship transfers. Page 31
    GAO/GGD-99-124 Taxpayer Advocate Office Appendix II Summary of
    Responses to the Taxpayer Advocate Staffing Survey 10.  Grade when
    entered PRP?  (Provide the person's grade level when he or she
    entered PRP.) Gradea
    Number of staff           Percentage of staff General Schedule-3
    5                            1.0 General Schedule-4
    38                            7.5 General Schedule-5
    43                            8.5 General Schedule-6
    36                            7.1 General Schedule-7
    77                           15.2 General Schedule-8
    13                            2.6 General Schedule-9
    99                           19.5 General Schedule-10
    2                            0.4 General Schedule-11
    70                           13.8 General Schedule-12
    54                           10.6 General Schedule-13
    47                            9.3 General Schedule-14
    11                            2.2 General Schedule-15
    6                            1.2 Executive Schedule-4
    1                            0.2 No response
    6                            1.2 Total
    508                        100.3 Note: Percentages do not equal
    100 due to rounding. a"Grade" means the level of classification an
    employee has under a position classification system (i.e.,
    referring to the duties, tasks, and functions he or she performs).
    11.  Report to?  (Provide the title and home function of the
    individual to whom the person reports.) Employee reports to
    Number of staff           Percentage of staff IRS managementa
    53                          10.4 Advocate Office managementb
    440                          86.6 Functional managementc
    81 . 6 No response
    7                            1.4 Total
    508                        100.0 a"IRS management" means the head
    of an IRS office or his or her designee. b"Advocate Office
    management" means the head of an Advocate office or his or her
    designee. c"Functional management" means the head of an IRS
    division, function, or functional unit, or his or her designee.
    Page 32                                                GAO/GGD-99-
    124 Taxpayer Advocate Office Appendix II Summary of Responses to
    the Taxpayer Advocate Staffing Survey 12.  Evaluated by?  (Provide
    the title and home function of the individual who evaluates the
    person's performance.) Employee evaluated by
    Number of staff           Percentage of staff IRS managementa
    53                           10.4 Advocate Office managementb
    423                            83.3 Functional managementc
    25                            4.9 No response
    7                            1.4 Total
    508                          100.0 a"IRS management" means the
    head of an IRS office or his or her designee. b"Advocate Office
    management" means the head of an Advocate office or his or her
    designee. c"Functional management" means the head of an IRS
    division, function, or functional unit, or his or her designee.
    13.  Percent of time currently spent on?  (Estimate the percentage
    of time the person currently spends on each type of work listed.
    Note:  Total should equal 100 percent.) Type of work
    Average percentage of time spent Advocacy
    10.4 Applications for Taxpayer Assistance Ordersa
    18.8 Congressional inquiries
    10.0 PRP cases
    19.0 Problem Solving Day cases
    9.4 Senate Finance Committee casesb
    4.7 Otherc
    27.8 Total
    100.1 Note: Average percentages are based on a total of 494
    Advocate Office staff. We received no response to this question
    for 14 Advocate Office staff. Percentages do not equal 100 due to
    rounding. aRequests for relief from hardship. bCases sent to IRS
    by the Senate Finance Committee. c"Other" includes types of work
    not in the categories above, such as program management and
    program support. Page 33
    GAO/GGD-99-124 Taxpayer Advocate Office Appendix II Summary of
    Responses to the Taxpayer Advocate Staffing Survey 14.  Training
    completed?  (Check all that apply.)  (Indicate the type of
    training that the person has completed for his or her current
    position.) Type of training
    Number of staff           Percentage of staff PRP course for
    current positiona                                    179
    35.2 PRP quality standardsb
    226                           44.5 PRP updatesc
    211                           41.5 PROMIS/Intelligent Queryd
    246                           48.4 Continuing professional
    education provided by IRS functions
    218                           42.9 On the job
    413                           81.3 No response
    47                                9.3 Note: Percentages are based
    on a total of 508 Advocate Office staff. Percentages total more
    than 100, because some respondents checked more than one response
    to this question. a"PRP course for current position" includes
    training for the positions of advocate, analyst, and PRP
    specialist. bStandards for doing PRP casework. cAnnual training to
    update Advocate Office and PRP staff on current issues and new
    laws affecting PRP. d"Intelligent Query" is a software package for
    generating specialized reports using the PROMIS database. Page 34
    GAO/GGD-99-124 Taxpayer Advocate Office Appendix III Summary of
    Responses to the Functional PRP Staffing Survey This appendix
    contains a summary of responses to the survey we sent to the 43
    local advocates and the advocate at the Office of the Assistant
    Commissioner (International). In that survey, we asked for
    information on each district office and service center employee
    assigned to functional PRP work as of June 1, 1998. We received
    responses for 2,215 staff-1,018 district office staff and 1,197
    service center staff. 1.  PRP role(s):  (Check all that apply.)
    (Indicate each person's role(s) in Survey Questions and    PRP.)
    Responses District office staff                Service center
    staff PRP role                                Number
    Percent            Number            Percent PRP manager
    69               6.8                   71                 5.9 PRP
    coordinator                                74               7.3
    152               12.7 PRP caseworker
    726               71.3               806               67.3 Othera
    175               17.2               188               15.7 No
    response                                    14               1.4
    25                 2.1 Note: Percentages are based on totals of
    1,018 for district office staff and 1,197 for service center
    staff. Percentages total more than 100, because some respondents
    checked more than one response to this question. a"Other" includes
    PRP roles not in the categories above, such as clerical support.
    Page 35                                                GAO/GGD-99-
    124 Taxpayer Advocate Office Appendix III Summary of Responses to
    the Functional PRP Staffing Survey 2.  Series?  (Provide the
    position series number.) District office           Service center
    staff                    staff Seriesa Occupationb
    Number Percent Number Percent 301        Miscellaneous
    administration & program                      15             1.5
    1         0.1 303        Miscellaneous clerk & assistant
    11             1.1        55         4.6 304        Information
    receptionist                                      0            0.0
    1         0.1 305        Mail & file
    0            0.0         8         0.7 318        Secretary
    27             2.7         1         0.1 322        Clerk-typist
    1            0.1         0         0.0 326        Office
    automation clerical & assistance                       0
    0.0         7         0.6 334        Computer specialist
    1            0.1         1         0.1 340        Program
    management                                            4
    0.4         1         0.1 343        Management & program analysis
    8            0.8        13         1.1 356        Data transcriber
    2            0.2         1         0.1 501        Financial
    administration & program                            2
    0.2        12         1.0 503        Financial clerical &
    assistance                               9            0.9
    111         9.3 512        Internal revenue agent
    130         12.8           17         1.4 525        Accounting
    technician                                         0
    0.0         9         0.8 526        Tax technician
    314         30.8           11         0.9 529        Not listed
    3            0.3         1         0.1 530        Cash processing
    1            0.1         0         0.0 579        Not listed
    1            0.1         0         0.0 582        Not listed
    5            0.5         0         0.0 592        Tax examining
    203         19.9          937        78.3 905        General
    attorney                                              2
    0.2         2         0.2 930        Hearing & appeals
    9            0.9         0         0.0 962        Contact
    representative                                     105
    10.3            0         0.0 963        Legal instruments
    examining                                   0            0.0
    1         0.1 987        Tax law specialist
    2            0.2         0         0.0 1101 General business &
    industry                                         2            0.2
    0         0.0 1169 Internal revenue officer
    123         12.1            1         0.1 3012 Not listed
    1            0.1         0         0.0 None No response
    37             3.6         6         0.5 Total
    1,018        100.1        1,197       100.3 Note: Percentages do
    not equal 100 due to rounding. a"Series" means a number
    identifying a recognized occupation in the federal service that
    includes all jobs at the various skill levels in a particular kind
    of work. b"Occupation" means an occupational series listed in the
    Handbook of Occupational Groups and Families developed by the U.S.
    Office of Personnel Management to aid federal agencies in
    classifying positions under the Classification Act of 1949 and
    P.L. 92-392. Page 36
    GAO/GGD-99-124 Taxpayer Advocate Office Appendix III Summary of
    Responses to the Functional PRP Staffing Survey 3.  Grade?
    (Provide the person's current grade level.) District office staff
    Service center staff Gradea                               Number
    Percent           Number             Percent General Schedule-3
    0                 0.0                 1                0.1 General
    Schedule-4                          16                 1.6
    69                 5.8 General Schedule-5
    32                 3.1               11                 0.9
    General Schedule-6                           6                 0.6
    76                 6.3 General Schedule-7
    199                19.6               645                53.9
    General Schedule-8                        102                10.0
    207                17.3 General Schedule-9
    353                34.7                78                 6.5
    General Schedule-10                          7                 0.7
    69                 5.8 General Schedule-11
    158                15.5                  8                0.7
    General Schedule-12                         94                 9.2
    20                 1.7 General Schedule-13
    41                 4.0                 5                0.4
    General Schedule-14                          5                 0.5
    1                0.1 General Schedule-15
    5                 0.5                 0                0.0 No
    response                                  0                 0.0
    7                0.6 Total                                   1,018
    99.9             1,197              100.1 Note: Percentages do not
    equal 100 due to rounding. a"Grade" means the level of
    classification an employee has under a position classification
    system (i.e., referring to the duties, tasks, and functions he or
    she performs). 4.  Permanent or detailed?  (Indicate whether the
    person is assigned to PRP work on a permanent or detailed basis.)
    District office staff                 Service center staff
    Assignment basis                     Number             Percent
    Number             Percent Permanent
    695                68.3              1120               93.6
    Detailed                                  296                29.1
    58                4.8 Othera
    10 . 1 20 . 2 No response                                 26
    2.6                17                1.4 Total
    1,018               100.1             1,197              100.0
    Note: Percentages do not equal 100 due to rounding. a"Other"
    includes temporary and seasonal assignments. Page 37
    GAO/GGD-99-124 Taxpayer Advocate Office Appendix III Summary of
    Responses to the Functional PRP Staffing Survey 5.  Full-time or
    part-time?  (Indicate whether the person is a full-time or part-
    time IRS employee.) District office staff               Service
    center staff IRS employment basis               Number
    Percent        Number         Percent Full-time
    952                 93.5         1,150                96.1 Part-
    time                                37                  3.6
    25                 2.1 No response                              29
    2.8            22                 1.8 Total
    1,018                 99.9         1,197               100.0 Note:
    Percentages do not equal 100 due to rounding. 6.  Percent of time
    on PRP work?  (Estimate the percentage of time the person does
    work related to PRP, including Problem Solving Day cases. Response
    should be 100 percent, unless the person also works outside of
    PRP.) Percentage of time               District office staff
    Service center staff spent on PRP work                  Number
    Percent        Number         Percent 1-24
    106                 10.4           417                34.8 25-49
    44                  4.3           199                16.6 50-74
    45                  4.4            78                 6.5 75-99
    94                  9.2            98                 8.2 100
    718                 70.5           383                32.0 No
    response                              11                  1.1
    22                 1.8 Total                                 1,018
    99.9         1,197                99.9 Note: Percentages do not
    equal 100 due to rounding. 7.  Years at IRS?  (Provide the number
    of years the person has worked at IRS.  Do not include other
    government experience.) District office staff
    Service center staff Years at IRS                       Number
    Percent        Number         Percent Less than 1
    3                 0.3              2                0.2 1-5
    44                  4.3            11                 0.9 6-10
    263                 25.8           219                18.3 11-15
    314                 30.8           405                33.8 16-20
    210                 20.6           216                18.0 More
    than 20                            157                 15.4
    323                27.0 No response
    27                  2.7            21                 1.8 Total
    1,018                 99.9         1,197               100.0 Note:
    Percentages do not equal 100 due to rounding. Page 38
    GAO/GGD-99-124 Taxpayer Advocate Office Appendix III Summary of
    Responses to the Functional PRP Staffing Survey 8.  Years in PRP?
    (Provide the number of years the person has done PRP work.)
    District office staff             Service center staff Years in
    PRP                               Number            Percent
    Number           Percent Less than 1
    375               36.8            166              13.9 1-5
    304               29.9            556              46.4 6-10
    205               20.1            312              26.1 11-15
    81                8.0              75              6.3 16-20
    10                1.0              17              1.4 More than
    20                                        2               0.2
    0              0.0 No response
    41                4.0              71              5.9 Total
    1,018            100.0            1,197            100.0 9.
    Position funded by?  (Check one.)  (Indicate the function that
    funds the person's position.) District office staff
    Service center staff Position funded by
    Number             Percent         Number            Percent
    Appeals                                          16
    1.6               0              0.0 Collection
    383                37.6            161              13.5 Customer
    Service Automated Collection System                    34
    3.3             12               1.0 Taxpayer Service
    183                18.0            422              35.3 Employee
    Plans and Exempt Organizations
    37                 3.6               1              0.1
    Examination                                     317
    31.1            244              20.4 Advocate Office
    12                 1.2               0              0.0 Othera
    21                 2.1            346              28.9 No
    response                                      15
    1.5             11               0.9 Total
    1,018            100.0             1,197            100.1 Note:
    Percentages do not equal 100 due to rounding. a"Other" includes
    IRS functions not in the categories above.  It also includes
    functions found only in service centers, such as Accounting,
    Taxpayer Relations, Adjustments, and Returns Processing. Page 39
    GAO/GGD-99-124 Taxpayer Advocate Office Appendix III Summary of
    Responses to the Functional PRP Staffing Survey 10.  How acquired
    by PRP?  (Check one.)  (Indicate how the person obtained a
    functional position in PRP.) District office staff
    Service center staff How position obtained                 Number
    Percent           Number             Percent Competed
    235                23.1              212                17.7
    Volunteered                                195                19.2
    204                17.0 Assigned
    315                30.9              645                53.9
    Detailed                                   221                21.7
    42                3.5 Othera
    46                4.5                51                4.3 No
    response                                   6                0.6
    43                3.6 Total
    1,018               100.0            1,197              100.0
    a"Other" includes methods not in the categories above, such as
    redeployment and assigned "as needed." 11.  Grade when entered
    PRP?  (Provide the person's grade level when he or she entered
    PRP.) District office staff                Service center staff
    Gradea                                Number             Percent
    Number             Percent General Service-3
    0                0.0                 5                0.4 General
    Service-4                            23                2.3
    63                5.3 General Service-5
    46                4.5                37                3.1 General
    Service-6                            34                3.3
    157                13.1 General Service-7
    303                29.8              592                49.5
    General Service-8                            45                4.4
    131                10.9 General Service-9
    266                26.1                63                5.3
    General Service-10                            5                0.5
    47                3.9 General Service-11
    141                13.9                 5                0.4
    General Service-12                           77                7.6
    18                1.5 General Service-13
    33                3.2                 3                0.3 General
    Service-14                            6                0.6
    0                0.0 General Service-15
    2                0.2                 0                0.0 No
    response                                  37                3.6
    76                6.3 Total
    1,018               100.0            1,197              100.0
    a"Grade" means the level of classification an employee has under a
    position classification system (i.e., referring to the duties,
    tasks, and functions he or she performs). Page 40
    GAO/GGD-99-124 Taxpayer Advocate Office Appendix III Summary of
    Responses to the Functional PRP Staffing Survey 12.  Report to?
    (Provide the title and home function of the individual to whom the
    person reports.) District office staff            Service center
    staff Employee reports to                        Number
    Percent        Number           Percent Advocate Office
    managementa                      308               30.3
    83              6.9 Functional managementb
    699               68.7         1,104             92.2 No response
    11                1.1            10              0.8 Total
    1,018           100.1            1,197            99.9 Note:
    Percentages do not equal 100 due to rounding. a"Advocate Office
    management" means the head of an Advocate office or his or her
    designee. b"Functional management" means the head of an IRS
    division, function, or functional unit, or his or her designee.
    13.  Evaluated by?  (Provide the title and home function of the
    individual who evaluates the person's performance.) District
    office staff            Service center staff Employee evaluated by
    Number            Percent        Number           Percent Advocate
    Office managementa                      287               28.2
    83              6.9 Functional managementb
    712               69.9         1,103             92.1 No response
    19                1.9            11              0.9 Total
    1,018           100.0            1,197            99.9 Note:
    Percentages do not equal 100 due to rounding. a"Advocate Office
    management" means the head of an Advocate office or his or her
    designee. b"Functional management" means the head of an IRS
    division, function, or functional unit, or his or her designee.
    Page 41                                                 GAO/GGD-
    99-124 Taxpayer Advocate Office Appendix III Summary of Responses
    to the Functional PRP Staffing Survey 14.  Percent of time
    currently spent on?  (Estimate the percentage of time the person
    currently spends on each type of work listed.  Note:  Total should
    equal 100 percent.) Average  percentage of time spent Type of work
    District office staff Service center staff Advocacy
    0.6                        0.5 Applications for Taxpayer
    Assistance Ordersa                                  4.5
    1.9 Congressional inquiries
    11.7                        3.5 PRP cases
    45.9                    40.4 Problem Solving Day cases
    12.0                        0.6 Senate Finance Committee casesb
    3.0                        0.3 Otherc
    22.4                    52.9 Total
    100.1                     100.1 Note: Average percentages are
    based on totals of 1,005 for district office staff and 1,174 for
    service center staff.  We received no response to this question
    for 13 district office staff and 23 service center staff.
    Percentages do not equal 100 due to rounding. aRequests for relief
    from hardship. bCases sent to IRS by the Senate Finance Committee.
    c"Other" includes types of work not in the categories above, such
    as functional work not related to PRP activities. 15.  Training
    completed?  (Check all that apply.)  (Indicate the type of
    training that the person has completed for his or her current
    position.) District office staff             Service center staff
    Type of training                               Number
    Percent         Number          Percent PRP course for current
    positiona                     416            40.9             471
    39.3 PRP quality standardsb                               680
    66.8             864             72.2 PRP updatesc
    548            53.8             886             74.0
    PROMIS/Intelligent Queryd                            248
    24.4             268             22.4 Continuing professional
    education provided by IRS functions                            506
    49.7             515             43.0 On the job
    861            84.6             995             83.1 No response
    36              3.5              52                4.3 Note:
    Percentages are based on totals of 1,018 for district office staff
    and 1,197 for service center staff. Percentages total more than
    100, because some respondents checked more than one response to
    this question. a"PRP course for current position" includes
    training for the positions of PRP manager, coordinator, and
    caseworker. bStandards for doing PRP casework. cAnnual training to
    update PRP staff on current issues and new laws affecting PRP.
    d"Intelligent Query" is a software package for generating
    specialized reports using the PROMIS database. Page 42
    GAO/GGD-99-124 Taxpayer Advocate Office Appendix IV Selected
    Survey Results for PRP Caseworkers Following are five tables with
    selected results from our survey of district office and service
    center functional employees assigned to PRP work as of June 1,
    1998. The results in this appendix are for the 726 district office
    and 806 service center staff who were identified as PRP
    caseworkers in the responses to our functional PRP staffing
    survey. Table IV.1: Funding Source of Functional PRP Caseworkers
    District office caseworkers                         Service center
    caseworkers Position funded by
    Number                    Percent                     Number
    Percent Appeals
    4                          0.6                       0
    0.0 Collection
    271                          37.3                    130
    16.1 Customer Service Automated Collection System
    30                          4.1                       6
    0.7 Taxpayer Service
    145                          20.0                    265
    32.9 Employee Plans and Exempt Organizations
    32                          4.4                       1
    0.1 Examination
    209                          28.8                    189
    23.4 Advocate Office
    8                          1.1                       0
    0.0 Othera
    14                          1.9                    208
    25.8 No response
    13                          1.8                       7
    0.9 Total
    726                         100.0                    806
    99.9 Note: Percentages do not equal 100 due to rounding. a"Other"
    includes IRS functions not in the categories above. It also
    includes functions found only in service centers, such as
    Accounting, Taxpayer Relations, Adjustments, and Returns
    Processing. Source: GAO survey. Table IV.2: Reporting Structure of
    Functional PRP Caseworkers District office caseworkers
    Service center caseworkers                          Total Employee
    reports to                        Number            Percent
    Number                Percent          Number              Percent
    Advocate Office managementa                    234
    32.2                 62                   7.7                296
    19.3 Functional managementb                         485
    66.8                744                  92.3            1,229
    80.2 Cannot determine                                 7
    1.0                  0                  0.0                  7
    0.5 Total                                          726
    100.0                 806                100.0             1,532
    100.0 a"Advocate Office management" means the head of an Advocate
    office or his or her designee. b"Functional management" means the
    head of an IRS division, function, or functional unit, or his or
    her designee. Source: GAO survey. Page 43
    GAO/GGD-99-124 Taxpayer Advocate Office Appendix IV Selected
    Survey Results for PRP Caseworkers Table IV.3: Evaluation of
    Functional PRP Caseworkers District office caseworkers
    Service center caseworkers                        Total Employee
    evaluated by                     Number               Percent
    Number              Percent           Number              Percent
    Advocate Office managementa                    214
    29.5                 62                7.7                276
    18.0 Functional managementb                         499
    68.7               744                92.3              1,243
    81.1 Cannot determine                                13
    1.8                 0                0.0                 13
    0.8 Total                                          726
    100.0               806              100.0               1,532
    99.9 Note: Percentages do not equal 100 due to rounding.
    a"Advocate Office management" means the head of an Advocate office
    or his or her designee. b"Functional management" means the head of
    an IRS division, function, or functional unit, or his or her
    designee. Source: GAO survey. Table IV.4: Training Completed by
    Functional PRP Caseworkers District office caseworkers
    Service center caseworkers                        Total Type of
    training                          Number               Percent
    Number              Percent           Number              Percent
    PRP caseworker course                          332
    45.7               335                41.6                667
    43.5 PRP quality standardsa                         550
    75.8               644                79.9             1,194
    77.9 PRP updatesb                                   436
    60.1               637                79.0             1,073
    70.0 PROMIS/Intelligent Queryc                      158
    21.8               132                16.4                290
    18.9 Continuing professional education provided by IRS functions
    400                55.1               380                47.1
    780                  50.9 On the job
    613                84.4               696                86.4
    1,309                   85.4 No response
    20                  2.8                22                2.7
    42                   2.7 Note: Percentages are based on totals of
    726 district office and 806 service center caseworkers.
    Percentages total more than 100, because some respondents checked
    more than one response to this question. aStandards for doing PRP
    casework. bAnnual training to update Advocate Office and PRP staff
    on current issues and new laws affecting PRP. c"Intelligent Query"
    is a software package used to generate specialized reports from
    the PROMIS database. Source: GAO survey. Page 44
    GAO/GGD-99-124 Taxpayer Advocate Office Appendix IV Selected
    Survey Results for PRP Caseworkers Table IV.5: Average Percentage
    of Time Spent by Functional PRP Caseworkers on Specific Types of
    Work Average percentage of time spent Type of work
    District office caseworkers          Service center caseworkers
    Total Advocacy
    0.4                                    0.1
    0.2 Applications for Taxpayer Assistance Ordersa
    5.3                                    2.2
    3.7 Congressional inquiries
    12.8                                     2.9
    7.6 PRP cases
    55.6                                   46.1
    50.6 Problem Solving Day cases
    10.0                                     0.6
    5.1 Senate Finance Committee casesb
    2.7                                    0.2
    1.4 Otherc
    13.3                                   47.8
    31.5 Total
    100.1                                    99.9
    100.1 Note: Average percentages are based on totals of 721 for
    district office caseworkers and 801 for service center
    caseworkers. We did not receive a response to this question for
    five district office caseworkers and five service center
    caseworkers. Percentages do not equal 100 due to rounding.
    aRequests for relief from hardship. bCases sent to IRS by the
    Senate Finance Committee. c"Other" includes types of work not in
    the categories above, such as functional work not related to PRP
    activities. Source: GAO survey. Page 45
    GAO/GGD-99-124 Taxpayer Advocate Office Appendix V Factors That
    Have Increased and Could Increase PRP Workload Factors that have
    increased and could increase PRP workload include PRP criteria
    that can be and have been broadly interpreted to include any
    situation; IRS initiatives, such as Problem Solving Days, Citizen
    Advocacy Panels, and the introduction of a PRP toll-free telephone
    number; and a legislative requirement designed to increase public
    awareness of advocate operations. PRP cases can be generated when
    a taxpayer contacts a local advocate Broad Interpretation of with
    a problem or when a front-line IRS employee, such as a customer
    PRP Criteria                    service representative, revenue
    officer, or revenue agent, determines that a situation should be
    referred to the Advocate's Office. The Internal Revenue Manual
    contains the following criteria for determining whether a
    situation qualifies as a PRP case: *  any contact on the same
    issue at least 30 days after an initial inquiry or complaint; *
    any contact that indicates the taxpayer has not received a
    response from IRS by the date promised; and *  any contact that
    indicates regular methods have failed to resolve the taxpayer's
    problem, or when it is in the best interest of the taxpayer or IRS
    that the case be worked in PRP. Officials in the Advocate's Office
    said that the way PRP criteria are interpreted had increased PRP's
    workload because the portion of the third criterion that reads "in
    the best interest of the taxpayer or IRS that the case be worked
    in PRP" can be interpreted so that any case qualifies as a PRP
    case. In that regard, the National Taxpayer Advocate said that he
    was committed to work any case for which a taxpayer was seeking
    help from PRP. In commenting on our draft report, the Commissioner
    of Internal Revenue stated that the PRP criteria had recently been
    modified. IRS has added the following four criteria: *  The
    taxpayer is suffering or is about to suffer a significant
    hardship; *  the taxpayer is facing an immediate threat of adverse
    action; *  the taxpayer will incur significant costs if relief is
    not granted (including fees for professional representation); and
*  the taxpayer will suffer irreparable injury, or long-term
    adverse impact if relief is not granted. Additionally, IRS deleted
    the portion of the third criterion that read, "in the best
    interest of the taxpayer or IRS that the case be worked in PRP."
    Because we received the information on the modified criteria as
    part of the Page 46                                   GAO/GGD-99-
    124 Taxpayer Advocate Office Appendix V Factors That Have
    Increased and Could Increase PRP Workload agency comment letter,
    we did not have time to evaluate the potential impact that the
    modified criteria might have on the PRP workload. IRS officials
    said that part of the PRP workload increase can be attributed IRS
    Initiatives Place      to an IRS initiative known as Problem
    Solving Days, which is the Demands on Program
    responsibility of the National Taxpayer Advocate. Continuation of
    that initiative and the recent start of two other IRS initiatives-
    Citizen Resources                  Advocacy Panels and publication
    of a unique toll-free telephone number for taxpayers to call the
    Advocate's Office-could place increasing demands on PRP resources.
    In November 1997, IRS began holding a series of monthly Problem
    Solving Problem Solving Days       Days in each of its 33
    districts. The purpose of these days is to give taxpayers with
    unresolved tax problems the opportunity to meet face to face with
    IRS staff in an effort to resolve those problems. These days have
    been advertised both locally and nationally through newspaper
    articles, television and radio interviews with IRS officials, and
    public service announcements. From November 1997 to November 1998,
    over 36,000 PRP cases were closed as a result of IRS' Problem
    Solving Days. According to local advocates, Problem Solving Days
    have not only provided taxpayers with in-person service but also
    allowed IRS staff to meet with taxpayers and help solve problems.
    However, the local advocates also said that the work involved with
    planning and executing these days and the subsequent increase in
    casework was taking its toll on Advocate and PRP staff. In
    addition to their other duties, some local advocates are
    responsible for Citizen Advocacy Panels    implementing Citizen
    Advocacy Panels within their districts. Collectively, the panels
    are designed to serve as advisory bodies to the Secretary of the
    Treasury and the Commissioner of Internal Revenue to improve IRS
    service and responsiveness. The panels are chartered to (1)
    provide citizen input into improving IRS customer service by
    identifying problems and making recommendations for improving IRS
    systems and procedures, (2) identify and elevate problems to
    appropriate IRS officials and monitor progress to effect change,
    and (3) refer taxpayers to the appropriate IRS office for
    assistance in resolving their tax problems. Membership on the
    panels is to include the local advocate and 8 to 15 citizens from
    the district. The South Florida District held the first public
    meeting of a Citizen Advocacy Panel in November 1998. Three more
    districts-Brooklyn, Midwest, and Pacific Northwest-have
    established panels and plan to hold public meetings during fiscal
    year 1999. Initially, IRS had planned to Page 47
    GAO/GGD-99-124 Taxpayer Advocate Office Appendix V Factors That
    Have Increased and Could Increase PRP Workload establish panels in
    each of its 33 districts. However, IRS is reevaluating this need
    in light of the agency's planned reorganization. According to
    local advocates, the Citizen Advocacy Panels represent a
    significant time commitment for them. Not only are the local
    advocates members of the panels, but they are also responsible for
    the administrative duties associated with the panels, such as
    securing space and equipment for meetings. In addition to time
    commitments for the local advocates, taxpayers may be referred to
    PRP for further assistance, which could increase PRP's workload.
    Local advocates said that the introduction of a toll-free
    telephone number PRP Toll-free Telephone    for taxpayers to call
    the Advocate's Office could increase PRP workloads. Number
    The number was operational as of November 1, 1998, and has been
    advertised in IRS publications, such as the tax year 1998 Form
    1040 tax package. IRS has used customer service staff as PRP
    telephone assistors to answer the calls, and the assistors have
    been equipped with computer systems that allow them to help some
    taxpayers immediately. There were 241,228 calls placed on this
    line between November 1, 1998, and April 17, 1999; and, according
    to the Advocate, 85 percent of these calls were for non-Advocate
    Office matters. The Advocate said that the procedure for the PRP
    toll-free assistors is to help any caller if the assistor has the
    time and ability; and if the assistor cannot help, the assistor
    should transfer the caller to IRS' general assistance phone lines.
    There is no way of determining whether taxpayers who were referred
    to local advocate offices through the toll-free line would have
    contacted IRS anyway or whether it was the availability of the new
    toll-free line that prompted them to contact PRP. Therefore, the
    actual increase in PRP cases, if any, cannot accurately be
    determined. However, local advocates were concerned that the toll-
    free line would dramatically increase PRP's future caseload. They
    were also concerned that this toll-free line would be inundated
    with calls from taxpayers needing general assistance-calls that
    would be better handled by another toll-free line that IRS has
    available for that purpose. Page 48
    GAO/GGD-99-124 Taxpayer Advocate Office Appendix V Factors That
    Have Increased and Could Increase PRP Workload A legislative
    requirement designed to increase public awareness of Legislative
    advocate operations may increase demands on PRP. The IRS
    Restructuring Requirement May        and Reform Act of 1998
    required IRS to include the address and telephone number of local
    advocates on statutory notices of deficiency sent to Increase
    Demands on    taxpayers.1  IRS began sending taxpayers the revised
    notice in August 1998. PRP                    The notices state
    that the taxpayers can contact their local advocate with their tax
    problem for "proper and prompt handling" if the problem is not
    resolved through normal IRS channels. IRS officials said that
    about 1 million statutory notices are sent out each year, and some
    portion of those taxpayers will probably be contacting the
    advocates, which will cause a corresponding increase in workloads.
    According to a local advocate, some taxpayers may have a
    legitimate reason to contact their local advocates. For example, a
    taxpayer may have repeatedly tried without success to rectify the
    problem addressed in the notice. Other taxpayers may contact their
    local advocates because the telephone number is made available. 1A
    statutory notice of deficiency is a legal notice that a tax
    deficiency exists and gives taxpayers the right to petition the
    Tax Court within 90 days (150 days for taxpayers outside the
    United States). If the taxpayer does not respond to this notice
    within this time period, the deficiency is to be assessed. Page 49
    GAO/GGD-99-124 Taxpayer Advocate Office Appendix VI PRP
    Performance Measures and Information Systems At the time of our
    review, the Advocate's Office used four measures to Performance
    Measures gauge PRP's performance. They were the (1) average
    processing time to close PRP cases, (2) currency of PRP case
    inventory, (3) quality of casework, and (4) case identification
    and tracking rate. Table VI.I shows actual performance results for
    the four measures for fiscal years 1996 through 1998. Table VI.1:
    Performance Results for the    Performance measure
    1996            1997           1998 Office of the Taxpayer
    Advocate (Fiscal    Average processing time (in days)
    38.2            33.4           37.8 years 1996-1998)
    Currency of case inventory (in days)                       n/aa
    n/aa        91.35 Quality of casework (percentage of standards
    met)                                             72.6
    83.7           80.8 PRP case identification (percentage of PRP-
    eligible cases that were identified as PRP cases in IRS service
    centers)                                           86.4
    87.0           86.3 aData for this measure were not collected
    until fiscal year 1998. Source: Office of the National Taxpayer
    Advocate. The first indicator, average processing time, represents
    the average number of days it took to close a PRP case. The
    measure does not include those cases that were opened and closed
    on the same day because these cases are not included in PRP's
    inventory control system. The measure also does not include those
    cases in which the Advocate's Office made a determination of
    hardship, which represent about 10 percent of the total PRP cases
    closed during fiscal year 1998. Hardship cases are not included in
    this measure because IRS requires that these cases be closed in 2
    days; including these cases might misrepresent the actual average
    closure times for PRP cases. The second indicator, currency of
    case inventory, is designed to measure the average number of days
    that cases have been in the open PRP inventory. The third measure,
    expressed as a percentage, is designed to determine the quality of
    PRP casework. This measure is to be based on a statistically valid
    sample of PRP cases and provides the National Taxpayer Advocate
    with data on timeliness and the technical accuracy of PRP cases.
    Each month, sampled cases are to be sent to two locations-one for
    district office cases and one for service center cases-for review.
    Reviewers at these locations are to check the cases against a list
    of 13 quality standards, broken into 3 categories-timeliness,
    communication, and accuracy. Each of the 13 standards is worth a
    certain number of points totaling 100. Cases are to be reviewed to
    determine if, among other things, the caseworker Page 50
    GAO/GGD-99-124 Taxpayer Advocate Office Appendix VI PRP
    Performance Measures and Information Systems contacted the
    taxpayer by a promised date, whether copies of any correspondence
    with the taxpayer appeared to communicate issues clearly, and
    whether the taxpayer's problem appeared to be completely resolved.
    The caseworkers and local advocate staff we talked with said that
    the quality measure was helpful because the elements that are
    reviewed provide a checklist for working PRP cases. According to
    staff, this helps ensure that most cases are worked in a similar
    manner in accordance with standard elements. The fourth measure,
    PRP case identification, is used only at the service centers and
    attempts to determine if service center employees are properly
    identifying potential PRP cases from incoming correspondence.
    Service center employees responsible for sorting the mail are also
    responsible for identifying potential PRP cases. The measure is to
    be based on a sample of mail coming into each service center.
    Analysts at the service centers are to review each sampled piece
    of incoming mail, identify potential PRP cases, and return the
    mail to the workflow. After the mail has been sorted and sent to
    the various service center units for handling, the analysts are to
    check to see what percentage of the sampled mail was correctly
    identified for PRP. The Taxpayer Advocate Management Information
    System is comprised of Information Systems    the Problem
    Resolution Office Management Information System (PROMIS), the
    Customer Feedback System, and the PRP Case Identification and
    Tracking System. PROMIS is a computerized inventory control and
    report system for PRP cases. Background information on PRP cases,
    such as the taxpayer's name, address, tax identification number,
    and a code to identify the taxpayer's problem are captured on the
    system. Additionally, in a case history section, the system
    captures a detailed description of the taxpayer's problem, along
    with what actions were taken, and when, to help the taxpayer. This
    system produces standard reports for the Advocate's Office and can
    be queried to produce other more specific reports, including
    reports for counts of information on any of its data fields, such
    as the number of cases opened or closed during a certain time
    period or at a certain location. The case history section cannot
    be queried as to what specific problems faced the taxpayers. All
    PRP cases, except those opened and closed in the same day, are to
    be entered into PROMIS. The Customer Feedback System was made
    necessary by the second Taxpayer Bill of Rights and is designed to
    capture taxpayers' compliments and complaints about IRS employees
    and what actions, if any were taken Page 51
    GAO/GGD-99-124 Taxpayer Advocate Office Appendix VI PRP
    Performance Measures and Information Systems regarding the cases.1
    If a taxpayer calls or writes IRS concerning the behavior of an
    employee, IRS managers are responsible for recording information
    on a customer feedback form. Additionally, forms are to be filled
    out if a manager receives a complaint of employee behavior from
    another IRS employee. After the forms are filled out, the
    information is compiled and reports can be generated. Reports
    include identifying what characteristics are more frequently
    described in customer complaints- such as the IRS employee using
    discourteous, unprofessional language. The system also collects
    data on what, if any, disciplinary actions-such as counseling or
    suspension-were taken against IRS employees. The PRP Case
    Identification and Tracking System is the system used to capture
    information on the PRP case identification measure. 1The Taxpayer
    Bill of Rights 2, P.L. 104-168 (July 30, 1996), section 1211,
    requires the Department of the Treasury to report annually to
    Congress on or before June 1, all instances of employee misconduct
    during the preceding calendar year and the dispositions of any
    such instances during that same year. Page 52
    GAO/GGD-99-124 Taxpayer Advocate Office Appendix VII Comments From
    the Internal Revenue Service Page 53     GAO/GGD-99-124 Taxpayer
    Advocate Office Appendix VII Comments From the Internal Revenue
    Service Page 54                                       GAO/GGD-99-
    124 Taxpayer Advocate Office Appendix VII Comments From the
    Internal Revenue Service Page 55
    GAO/GGD-99-124 Taxpayer Advocate Office Page 56    GAO/GGD-99-124
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