We welcome back guest blogger Barbara Heggie. Barb is the supervising attorney for the Low-Income Taxpayer Project of 603 Legal Aid in Concord, New Hampshire. Her clinic serves taxpayers through the Granite State and is the only LITC in the state. Today, she describes a recent experience in trying to assist a client. Her effort reminds us of the difficulties facing taxpayers and practitioners trying to reach the IRS in the first place and trying to reach the “right” part of the IRS. We recently discussed one of the impediments to reaching the IRS in our post on fee based calling which pushes human callers to the back of the line. Keith
Most people think of the autonomic nervous system as confined to such unconscious bodily processes as breathing, digestion, and heart rate. But most of you reading this have probably added another to the list – (re)dialing the IRS. Pandemic-related staffing shortages, antediluvial technology, and a private robocalling industry have teamed up to render uncertain the once-inviolable privilege of being placed on hold for an hour. Instead, any attempt to reach the IRS by phone, even via the Practitioner Priority Service (PPS), will likely end with this now-familiar recording: “We are sorry, but due to extremely high call volume in the topic you requested, we are unable to handle your call at this time.” A new callback option can spare us the slow torture of short-looped, wondrously-insipid hold music, but it can’t spare us the agony of trying to get there.
read more...Dial, redial, repeat.
This is all the more agonizing when we realize that a few well-placed, taxpayer-centric changes at the IRS could make this time suck a complete non-necessity. The National Taxpayer Advocate (NTA), Erin Collins, has written here and here about the robocalling problem and the low levels of telephone service at the IRS. And see here for several seemingly doable suggestions regarding economic hardship and collection processes by former NTA Nina Olson in her 2018 Annual Report to Congress.
Last week, I called PPS for a disabled domestic violence survivor subsisting solely on $1,020/month in Social Security Disability Insurance payments. She has a joint tax liability with her estranged husband, and she’s terrified he’ll get to her through the IRS. Each new collections notice sent her to the phone, anxious to explain her circumstances and request some sort of forbearance. But she couldn’t get past the “extremely high call volume.”
She came to me for help, and we decided I would start by asking the IRS to (1) record her balance-due accounts currently not collectible, due to financial hardship, and (2) place a domestic violence marker on all her accounts to prevent the IRS from releasing any of her contact information to an unauthorized person, including her husband. Conceivably, each of these requests could be made in writing, but much harm could come to this client while waiting for the IRS to process such submissions. A call to the IRS was required.
After dialing PPS sixteen times, each attempt involving a must-listen to various recorded messages, I made it onto the queue. Huzzah! I readily agreed to the callback option and got connected to a customer service representative (CSR) a half an hour later, just as promised. He placed a Victim of Domestic Violence (VODV) marker on my client’s accounts but said he could not record her balances uncollectible. I was surprised, given that I had chosen the menu option for “individual accounts already in collections, ACS.” Moreover, for balances at my client’s level, the Internal Revenue Manual requires no Collection Information Statement (CIS) if the only source of income is Social Security. But there had been a change in procedures, the CSR explained, and he offered to transfer me to the “real” Automated Collection System (ACS), where someone could do as I had requested.
Rather than have him transfer me, however, I decided to call PPS again – not because I thought a different CSR would give me a better answer, but because this one wasn’t able to send me the transcripts I wanted due to some equipment failure he was experiencing, and I wasn’t sure an ACS CSR would have the authority to do this. I hadn’t been able to retrieve the transcripts myself from the IRS Transcript Delivery Service (TDS) because . . . I don’t know. The CSR affirmed I had been listed on the accounts as an authorized representative for several days, but TDS said otherwise and refused to give up the transcripts. (This doesn’t appear to be an isolated incident; recently, many others in the Low-Income Taxpayer Clinic community have reported the same problem.)
Thus, I called PPS again.
Dial, redial, redial,
redial, redial, redial,
redial, redial, redial,
redial, redial, redial.
Just twelve times! The second PPS CSR got me the transcripts but said the same thing as the first one; the CNC request can only be handled by ACS personnel, no matter the circumstances. (A week later, TDS is still denying me access to these accounts.)
The CSR offered to transfer me to ACS, and this time I agreed. After a few minutes, another CSR picked up the line, and I made my simple pitch: please record my client’s balance-due accounts as uncollectible because her only income is Social Security and she’s experiencing financial hardship. This CSR, #3 of the day, said he couldn’t see any debt under my client’s SSN – and, therefore, couldn’t help me. I stressed it was a joint liability, with my client listed as the secondary on the account. The CSR responded that this explained the problem and asked if I had any other questions. Telling him that the previous two CSRs of the day hadn’t had any such problem left him unfazed. When he suggested transferring me to “Collections,” I agreed, not bothering to ask where I had been the whole time.
The beauty of a unit-to-unit transfer is that you bypass the hold queue and go straight to a CSR picking up your line. At least, that’s how it used to be. This time, it took over two hours – the longest hold time I’ve ever encountered. Luckily, however, CSR #4 of the day was able to both see and do. I made my pitch for uncollectible status and explained the client’s income stream. The CSR verified the Social Security income, found no other sources, and granted the request for uncollectible status. As expected, she didn’t require a CIS. And by then, it was bedtime.
Fans of the Python-esque film Brazil may find some commonalities.
What else is there to say about IRS on Good Friday? Forgive them; for they know not what they do.
I too have encountered nearly intolerable wait times while calling the PPS and even longer when calling particular divisions (Exempt Organizations). I say though that my interactions with the PPS employees have been far and away positive. I do not think the people are the issue. Also, I concur in the delays of getting my POAs entered so I can use the TDS and stay off of the phone. It would seem that the CAF Unit could use some help, which would reduce the need for phone calls by practitioners. Finally, I do still write, although most every writing of significance requires follow-up and most require help from the TAS. Yes, our IRS has problems, but we as practitioners have to adapt and, if all else fails, avail ourselves of the courts for resolution.
I have one that might even be more horrific: my client also subsists on social security, while he is bedridden with numerous ailments and Alzheimer’s. It doesn’t get much worse. However, the IRS decided to levy on his social security anyway. My 911 Application For Taxpayer Assistance Order last summer was ignored, so I submitted another one, this time with many pages of medical records. No response. After two months, I would start getting monthly voice mails telling me they were working on the case. No status report, nothing. But what was there to work on? Fast forward to April 2022, nothing from the Taxpayer Advocate Service (by the way, I also faxed the package to the National Taxpayer Advocate without response.) Not the same as calling forever, but indicative of a failing bureaucracy.
These concerns are too familiar and yet still mind-boggling. PPH was set up to help practitioners who are typically charging their clients for the calls, yet practitioners are required to redial numerous times and then wait on hold for hours, which ultimately results in larger fees to the taxpayer and less money to pay the IRS. I do think it is in part the agents. Last week I called ACS to get a 180-day extension of time to pay placed on a client’s account to give the IRS time to review her penalty abatement request, and the agent who picked up the phone was immediately snippy with me. I had waited on hold over an hour, and then when she picked up my computer decided to freeze for a moment so I was unable to immediately access my POA, and yet instead of giving me a moment to let my computer stop bugging out, the IRS agent asked to “put me on hold for up to 5 minutes” – why would you do that when I have not given you any information yet? Obviously the agent wanted a break or to check her phone or something. And so I was faced with a difficult choice – do I hang up and try again to get a nicer agent, perhaps not even being able to reach an agent for days, or do I just accept she will be difficult and perhaps incompetent? I stayed on the line and was able to obtain the 180-day extension. However, the agent declined to provide me the account transcripts I requested because of “computer issues” on her end (very vague and I’m 100% sure she was lying, but you can’t fight someone with such an attitude). I understand it must be difficult to work for the IRS and deal with complaining people all day long. Nevertheless, ACS and PPH provide important functions, now more than every before as IRS mail may go unread for months. I have always asked why the IRS does not have a division similar to OPR to allow tax professionals and taxpayers to complain about the bad actions of IRS employees. A little accountability could go a long way.
Amen,
Bob Sable
Greater Boston Legal Services
In case anyone thinks these might be rare instances of malfunction, let me give the short version of another long tale of telephone woe.
I started a call to PPS at about 3:20 this afternoon to request uncollectible status for a destitute client in collections. It took 19 tries just to get placed on hold for 40 minutes. Then, after the preliminary 45 minutes, I got transferred to ACS, as expected. Over an hour later, after jumping through all the hoops — but JUST before the CSR was about to grant my wish — the line dropped. It was then after 5:30. I called back, got through after just three dials, and was blessed with the option to have the IRS call ME back in an hour. So, I drove home, had dinner, and got some laundry done.
Then the IRS called, and I was placed on hold for an hour and twenty minutes. The person who eventually picked up the phone was in Accounts Management, not ACS, so she transferred me to ACS, where I spoke with someone just about to go off her shift. She tried to do what was needed in time but couldn’t, so she transferred me to someone else. Fortunately, this person was able to help. It was the fifth person I spoke with and the third one I faxed over the power of attorney authorization. But it’s done — as of 8:45 pm.
I doubt anyone thinks your story is rare. Welcome to my world.
I spent an hour on hold with Social Security — a minor inconvenience compared to the examples here. It bothers me when they say they have unusually long wait times. Because the wait times are always long, what do they mean by “unusual?” It is hard to hear that recorded message as anything other than, “We know we have a problem, but we are not willing to fix it.”