TREASURY
INSPECTOR GENERAL FOR TAX ADMINISTRATION
Inaccurate and Incomplete Data Have Adversely Affected
Implementation of the
May 16, 2008
Reference Number: 2008-40-118
This report has cleared the Treasury Inspector General for Tax Administration disclosure review process and information determined to be restricted from public release has been redacted from this document.
Phone Number |
202-622-6500
Email Address | inquiries@tigta.treas.gov
Web Site |
http://www.tigta.gov
May 16, 2008
MEMORANDUM FOR COMMISSIONER, WAGE AND INVESTMENT DIVISION
FROM: Michael R. Phillips /s/ Michael R. Philips
Deputy Inspector General for Audit
SUBJECT: Final Audit Report – Inaccurate
and Incomplete Data Have Adversely Affected Implementation of the
This report presents the results of our review to assess the
accuracy and completeness of the data compiled for use in the Internal Revenue
Services’ (IRS) Taxpayer Assistance Center (hereafter referred to as a TAC or
Center) assessment process. This audit was conducted as part of
the Treasury Inspector General for Tax Administration Office of Audit Fiscal
Year 2008 Annual Audit Plan.
Impact on the Taxpayer
Since Fiscal Year 2003, we have reported on the IRS’ inability to
compile and maintain accurate and complete management information to oversee
and measure the effectiveness of its TAC Program. Key management information used to make
decisions and support Program changes continues to be either absent or based on
inaccurate/incomplete data. This hinders
the IRS’ ability to make appropriate decisions when determining TAC locations
and the services they provide taxpayers seeking face-to-face assistance and has
delayed the IRS in making any decisions on the TAC Geographic Footprint, which
is an important initiative within the Taxpayer Assistance Blueprint (Blueprint).
Synopsis
Congress directed the IRS
to perform a comprehensive review of its current portfolio of taxpayer services
and develop a 5‑year plan.
The
IRS suggests taxpayers visit the Centers when they have complex tax issues,
need to resolve tax problems relating to their tax accounts, have questions
about how the tax law applies to their individual income tax returns, or feel
more comfortable talking with someone in person. In May 2005, the IRS announced plans to
close 68 Centers nationwide. In
response to this announcement, Congress proposed language to be included in the Department of the Treasury
Appropriations Act, 2006,[1] that would delay the closing of any Centers. In addition to requiring the Treasury
Inspector General for Tax Administration to review the accuracy of the
estimated cost savings of the reduced taxpayer services, Senate Committee
Report 109-109[2] directed the IRS to do a comprehensive
review of its current portfolio of taxpayer services and to develop a 5‑year
plan that outlines the services it should provide to improve services for
taxpayers.
To fulfill the Congressional mandate, the IRS formed a team to create the Blueprint in a two‑phase process. The Blueprint Phase 1 report issued in April 2006 identified strategic improvement themes by researching IRS services relative to taxpayers’ needs and preferences. The Blueprint Phase 2 report issued in April 2007 devoted an entire section to the TACs. It provides a step-by-step process for future decisions regarding Center locations, called the TAC Geographic Footprint.
Inaccurate and incomplete management information continues
to delay implementation of the TAC Geographic Footprint. The IRS cannot measure the effectiveness of
the TAC Program without accurate and complete data. Since Fiscal Year 2003, the IRS has assigned
responsibility for developing accurate TAC Program data to different executives
and executive-led teams, with limited success.
The Blueprint established
26 taxpayer and Federal Government criteria for use in making future decisions
regarding Center locations. The IRS
eliminated 6 of the 26 criteria and added 21, for a total of 41 criteria.
Nineteen
(46 percent) of the 41 criteria contained inaccurate or incomplete
data. The IRS identified 8 criteria, and
we identified an additional 11 criteria that contained inaccurate or
incomplete data.
We tested data in 33 of the 41 criteria. We did not test data in eight criteria because the IRS had already determined that these criteria contained inaccuracies. Our tests determined that 11 additional criteria contained inaccurate or incomplete data–for a total of 19 (46 percent) of 41 criteria with inaccurate or incomplete data.
For the most part, the eight criteria the IRS identified as containing inaccurate data involve the Field Assistance Office’s[3] management information systems and how the IRS tracks Center activity and employee workload. The 11 data criteria we identified as inaccurate related to TAC real estate and employee costs. For example, the IRS inaccurately calculated rent costs, square footage, and the number of TAC employees currently on the payroll. We reported these same errors in Fiscal Year 2005, noting that this is typical information that any function should have readily available to operate effectively.[4]
Although the
Field Assistance Office has implemented two new systems to capture and process
employee time and customer data, these systems
still do not capture budget and/or operating costs by Center, including rent,
personnel, and overhead. Attempts to
capture these data have been unsuccessful.
Without these data, the IRS cannot 1) accurately determine costs
associated with the Centers, 2) determine the cost effectiveness or return on
investment[5] for the TAC Program, or 3) make any
decisions on which Centers to close.
The IRS has
not yet determined which taxpayers it can most effectively serve with its
TAC Program.
In addition, the optimum locations for the Centers and which taxpayers
they most effectively serve have not been determined. The
Blueprint represents the first large-scale effort to attempt to collect data
specific to TAC customers. However, as
the IRS recognizes, the survey results do not clearly distinguish
between TAC users and non-TAC users to enable
it to effectively draw conclusions about the characteristics of individuals who
use TAC services. The IRS plans to
continue to conduct surveys in Fiscal Year 2008. It must continue to develop data about which
customers are best served by the TAC Program to develop and deliver an
effective customer service strategy.
Finally, the IRS is unable to measure how closing Centers might affect taxpayers and compliance. In March 2006, we reported that the IRS could not determine the effect Center closures might have on taxpayer compliance. The IRS did not have the means to capture all interactions between a TAC employee and a taxpayer to determine why the taxpayer visited a Center, what service he or she received, and– most importantly–the effect the service or action has on the taxpayer’s future compliance. The IRS is not planning to conduct specific projects that assess the impact on compliance when closing Centers. However, research projects are planned for Fiscal Years 2008 and 2009 to determine the impact taxpayer service has on compliance, including the services provided at a Center. Therefore, we are making no recommendations regarding this issue.
We have made prior recommendations concerning the Field Assistance Office’s management information systems and the problems with inaccurate and unreliable data. The IRS agreed to these recommendations and has been working on corrective actions (particularly with the research efforts related to the Blueprint) and developing a new Field Assistance Office management information system. Because many of the concerns we identified in prior audits remain, we are making the same recommendations in this report.
Recommendations
We recommended that the Commissioner, Wage and
Investment Division, should 1) improve the management information system to
capture the number of taxpayers served, the numbers and types of services
provided, and the related resources (costs); 2) develop and implement an
internal control system to ensure management information data are accurate and
reliable; and 3) develop a process that includes routine assessments of TAC
operations to ensure that the TACs are optimally located and the services
provided at the TACs are the most effective and cost efficient.
Response
IRS management agreed with two of our three recommendations and partially agreed with one recommendation. They will continue to capture data they are currently collecting because the data are sufficient to identify taxpayers’ needs and the services provided. They do not agree to capture detailed information regarding each individual service because it is cost and resource prohibitive. The IRS will validate and certify the accuracy of information provided for all real estate data elements. Updated information for real estate data elements will be provided to the Wage and Investment Division in May 2008. The TAC space assignment information will be provided subsequent to the ongoing TAC space validation process targeted for completion in July 2008. Because the real estate information provided in support of the TAC Geographic Footprint is not static, it will be kept updated on a quarterly basis beginning in the fourth quarter of Fiscal Year 2008. Finally, the Field Assistance Office will use the process developed by the Geographic Coverage Initiative to create a balanced footprint designed to maximize taxpayer needs and services provided. Management’s complete response to the draft report is included as Appendix VI.
Office of Audit Comment
The IRS disagreed that it is unable to identify which taxpayers are most effectively served in the TACs. However, to date, much of the IRS’ understanding of taxpayer needs, preferences, and behaviors is based on results of taxpayer responses to four surveys[6] reported in the Blueprint Phase 2 report. As the IRS recognizes, the survey results do not clearly distinguish between TAC users and non-TAC users to enable it to effectively draw conclusions about the characteristics of individuals who use the services of a Center. The IRS plans to continue to conduct surveys in Fiscal Year 2008.
In its overall discussion of the report, the IRS also stated that it believed this audit to be premature, because IRS personnel had expressed concerns regarding the accuracy of the data elements used to populate the Evaluative Model. We do not agree. Over the last 4 years, we have reported on the IRS’ inability to compile and maintain accurate and complete management information to oversee and measure the effectiveness of its TAC Program. In response, the IRS has developed and implemented three different models in which to capture data to make decisions and support TAC Program changes. The third and current model, the Geographic Coverage Initiative, incorporates the Geographic Coverage Rate Model, and in fact incorporates many of the recommendations made in this and prior Treasury Inspector General for Tax Administration reports, including how to ensure the data are kept accurate and current.
Finally, although the IRS did not agree to capture detailed information regarding each individual service taxpayers receive at the TACs because it is cost and resource prohibitive, it stated that information from the Contact Recording System,[7] along with the Field Assistance Management Information System and Business Objects,[8] will be sufficient to capture taxpayer needs and services provided. We believe these systems together might provide sufficient information, and we will conduct followup testing during our planned Fiscal Year 2008 audit of the Field Assistance Management Information System.
Please contact me at (202) 622-6510 if you have questions or Michael E. McKenney, Assistant Inspector General for Audit (Wage and Investment Income Programs), at (202) 622-5916.
Appendices
Appendix
I – Detailed Objective, Scope, and Methodology
Appendix
II – Major Contributors to This Report
Appendix
III – Report Distribution List
Appendix
IV – Treasury Inspector General for Tax Administration Audit Reports
Appendix
V – Taxpayer and Federal Government Taxpayer Assistance Center Evaluation
Criteria
Appendix
VI – Management’s Response to the Draft Report
Abbreviations
|
IRS |
Internal Revenue Service |
|
TAC |
|
|
TIGTA |
Treasury Inspector General for Tax
Administration |
The Internal Revenue Service (IRS) provides taxpayers with the option of obtaining personal, face‑to‑face tax assistance at 401 Taxpayer Assistance Centers (hereafter referred to as a TAC or Center) nationwide. The IRS suggests taxpayers visit the Centers when they have complex tax issues, need to resolve tax problems relating to their tax accounts, have questions about how the tax law applies to their individual income tax returns, or feel more comfortable talking with someone in person.
In May 2005, the IRS announced plans to close 68 TACs nationwide. In response to this announcement, Congress proposed language to be included in the Department of the Treasury Appropriations Act, 2006,[9] that would delay the closing of any Centers. The Committee on Appropriations stated in the Senate Report:
. . . Due to the Committee’s
concerns, the Committee has included an administrative provision that prohibits
the use of funds provided in this Act for purposes of reducing any taxpayer
service function or program until the Treasury Inspector General for Tax
Administration [TIGTA] has completed a study detailing the impact of the IRS’
plans to reduce services on taxpayer compliance and taxpayer assistance. The Committee also requests [the] TIGTA to
review the accuracy of the estimated cost-savings [sic] of the reduced
services.[10]
Subsequently, a law was passed[11] delaying the closure of any TACs.
The Taxpayer
Assistance Blueprint and the TAC Geographic Footprint
In addition to requiring us to review the
accuracy of the estimated cost savings of the reduced taxpayer services, Senate
Committee Report 109-109 directed the IRS to do a comprehensive review of its
current portfolio of taxpayer services and to develop a 5-year plan that
outlines the services it should provide to improve services for taxpayers.
To fulfill the Congressional mandate, the IRS formed a team to create the Taxpayer Assistance Blueprint (Blueprint). To satisfy the report submission date of April 14, 2006, the IRS designed the Blueprint to be completed in a two‑phase process. The Blueprint Phase 1 report issued in April 2006 identified strategic improvement themes by researching IRS services relative to taxpayers’ needs and preferences.
The Blueprint Phase 2 report was issued
April 2007. It devoted an entire
section to the TACs, stating that unique challenges are presented by each TAC’s
operating environment. Therefore, the
IRS conducted an analysis separate from the rest of the Blueprint Service
Improvement Portfolio. The Blueprint
Phase 2 report provided a step-by-step process for future decisions regarding Center
locations, called the TAC Geographic Footprint.
The Blueprint Phase 2 report
stated the TAC evaluative process was to involve three phases, as outlined in
Figure 1.
Figure
1: The Three Phases of the TAC
Evaluative Process
|
Phase 1 – Categorize each TAC to
identify those facing staffing and real estate activities in the near term,
as well as those currently providing low or redundant population
coverage. Identify those TACs in these
categories and evaluate them based on the 26 taxpayer and Federal Government
value criteria. Create a list of any
recommended closures of the TACs deemed appropriate after full consideration
of the applied criteria. |
|
Phase 2 – Bring recommended
closures to the IRS Services Committee[12]
some time after the end of the filing season[13]
in Calendar Year 2007. Manage
implementation of approved recommendations to minimize negative impact on
taxpayers, employees, partners, and filing season operations. This process is expected to last into
Calendar Year 2008. |
|
Phase 3 – Continue evaluation of
all remaining TACs in terms of all taxpayer and Federal Government value
criteria and consideration of business rules.
Submit additional recommended closures to the IRS Services Committee. Throughout the process, consider whether
the evaluative criteria and process require modification based on lessons
learned during Phases 1 and 2. |
Source: The 2007 Blueprint Phase 2 report.
This review was performed at the Field Assistance
Office, Taxpayer Services Program Management Office, and the Strategy and
Finance Research offices in the Wage and Investment Division in
Inaccurate and Incomplete Management Information Continues to Delay Implementation of the Taxpayer Assistance Center Geographic Footprint
Since Fiscal Year 2003, we have reported on the IRS’ inability to compile
and maintain accurate and complete management information to oversee and measure
the effectiveness of its TAC Program. Key
management information used to make decisions and support Program changes is either
absent or based on inaccurate and/or incomplete data, including how the IRS
tracks TAC activity, employee workload, TAC real estate, and employee
cost. This hinders the IRS’ ability to
make appropriate decisions when determining Center locations and the services they
provide taxpayers seeking face-to-face assistance and has delayed the IRS in making
any decisions on the TAC Geographic Footprint, which is an important initiative
within the Blueprint. Compiling and
maintaining accurate management information is essential because 119 (30
percent) of the 401 TAC leases expire in Fiscal Years 2008 and 2009, providing
the IRS an opportunity to determine if the current locations are the most
optimal and/or identify better locations for the 119 Centers.
Additionally, the IRS cannot measure the effectiveness of the TAC
Program without accurate and complete data.
As a result, it has no assurance that the Fiscal Year 2007 budgetary
expenditures–in excess of $157 million–were used effectively or that budgets in
the future will be effectively spent. Fiscal
Year 2007 budgetary expenses included more than $132 million for employees
working in the Centers and more than $10 million for management oversight
of the TAC Program. Management oversight
included 4 directors, 180 managers (32 in Headquarters and Area Offices and 148
in the TACs), and 76 national analysts, field analysts, and technical
advisors. An Area
Office is a geographic organizational level used by IRS business units and
offices to help their specific types of taxpayers understand and comply with
tax laws and issues.
Data inaccuracies and inconsistencies have been reported since Fiscal Year 2003
Since Fiscal Year 2003, the IRS has assigned responsibility for developing
accurate TAC Program data to different executives and executive-led teams, with
limited success. Figure 2 provides a timeline
of findings from prior TIGTA reports relating to concerns about the TAC
Program’s management information and related events and actions.[14]
Figure 2: Timeline of Prior TIGTA Reports and Related
Events and Actions
|
August
2003 |
We report that the IRS’ estimation of the number of
taxpayers who visit the Centers could be substantially understated due to
inconsistencies in tracking visits, use of multiple tracking systems, and a
manual process of inputting visits to a management information system. The IRS responds that it plans to install at each
of its Centers an automated tracking system that will allow it to more
accurately track taxpayer visits by providing a networked system that
captures data on customer volumes and the types of service requested by
taxpayers. |
|
May 2005 |
The IRS announces
plans to close 68 TACs. |
|
June 2005 |
Congress reacts to the
report of the IRS’ decision to close 68 TACs and proposes to delay the
closings until we have completed a study of how the IRS’ plans to reduce
services will affect taxpayer compliance and taxpayer assistance. |
|
July 2005 |
We complete an audit of the TAC Program service
delivery and report that key management information used to make decisions
and support changes for TACs is either absent or based on incomplete
data. The IRS agrees that improving
its management information system is critical and plans to develop a
web-based management information system that will provide critical program
planning and control information at the local and national levels. The IRS halts plans to close any Centers. |
|
February 2006 |
We complete an audit on
taxpayer services and report that the IRS has conducted only limited research
on the impact of customer service on taxpayer compliance. The IRS agrees that further study is warranted regarding
the impact on taxpayer compliance of any reduction in services and states it
is awaiting the results of both the Blueprint and our audit of the TAC Closure
Model (this Model was used to identify which Centers to close). |
|
March 2006 |
We complete
an audit of the TAC Closure Model, report inaccuracies and inconsistencies in
the data used to populate the Model, and raise concerns about using the
results to select which Centers to close and determining the associated cost
savings that may be achieved. The IRS agrees data reliability is
an issue that must be addressed, stating it will ensure that data used in any
decision-making tool as they relate to the TAC Program are accurate and
verified. |
|
April 2006 |
The IRS issues the Blueprint Phase
1 report. |
|
April 2007 |
The IRS issues the Blueprint Phase
2 report. |
|
May 2007 |
The
IRS forms a Validation Team to validate the accuracy of the data gathered on
the TAC Program by the Blueprint team.
A decision is made to scrap the TAC Closure Model and to continue to build
a new model (the TAC Evaluative Model) to make decisions regarding the TAC
Program. |
Source: TIGTA audit reports, Blueprint Phase 1 and 2 reports, Congressional action, and interviews with IRS employees.
Data used to populate the current Evaluative Model are either inaccurate or incomplete
The current Evaluative
Model was built as part of the Blueprint initiative to develop a service
delivery plan and establish a Geographic Footprint for the TAC Program. The Blueprint established 26 taxpayer and Federal
Government criteria for use in making future decisions regarding Center
locations. The Validation Team eliminated
6 of the 26 criteria and added 21, for a total of 41 criteria.[15]
In June 2007, we met
with representatives from the Validation Team who stated they were conducting a
comprehensive validation of the data included in the Evaluative Model. The goal was to ensure that all data were fully
validated so the Evaluative Model and the Geographic Footprint could be used to
make decisions as to which Centers to close.
In September 2007, IRS
management advised us that the Validation Team had raised concerns about the
accuracy of the data used to populate the Evaluative Model. Specifically, the Validation Team indicated that
eight criteria contained inaccurate data.
As a result, the Validation Team stopped all work on the Evaluative
Model, and the IRS transferred responsibility for compiling and validating data
to the Field Assistance Office, which is responsible for oversight of the TAC
Program. Additionally, the
Validation Team was unable to develop a process to keep the data accurate and
current.
Our review consisted of testing data in 33 of the 41 criteria included in the Evaluative Model. We did not test data in eight criteria because the IRS had already determined that these criteria contained inaccuracies. Our tests determined that 11 additional criteria contained inaccurate or incomplete data, for a total of 19 (46 percent) of 41 criteria with inaccurate or incomplete data.
The Government Accountability Office Standards for Internal Control in the Federal Government[16] require information to be recorded and communicated to management and others within the entity who need it and in a form and within a time period that enables them to carry out their internal control responsibilities. For an entity to run and control its operations, it must have relevant, reliable, and timely communications relating to internal as well as external events.
Criteria contained inaccuracies involving TAC Program taxpayer activity and employee workload
For the most part, the eight criteria the IRS identified as containing inaccurate data involve the Field Assistance Office’s management information systems and how the IRS tracks TAC activity and employee workload. For example:
We previously reported[19]
that Field Assistance Office systems do not accurately track activity and do
not capture all TAC services. This Office also was using four separate systems to obtain management
information on taxpayer contacts and employee workload–most of which were paper-based,
labor-intensive, manual systems. The IRS
acknowledged that prior Field Assistance Office management information systems
could not be relied on for timely, accurate workload performance information
due to the manual process of recording taxpayer visits.
In Fiscal Year 2002, the Field Assistance Office began installing the Q-MATIC in the Centers. It is an automated queuing system used to control the flow of taxpayers waiting
for assistance. In most Centers, the Q-MATIC automatically records the number of taxpayers
assisted. Additionally, in
Fiscal Year 2007, the Field Assistance Office implemented the Field
Assistance Management Information System to replace the older manual reporting
system. The Field Assistance Management
Information System is a web-based system that captures and processes employee
time‑reporting information and customer data. It automatically imports data from the Q‑MATIC
(e.g., tax issues and time spent in service), then associates the data with the
login of the technical employee who provided the service.
The current tracking
system is able to capture only the most significant service provided to each
taxpayer.
In Fiscal Year 2007, Field Assistance Office employees were told to
track all assistance they provided to customers in the Centers by using more
than one code per taxpayer if they helped a taxpayer with multiple services
during one contact. However, problems arose, and the Field Assistance Office is again able
to capture only the most significant service provided to each
taxpayer. When multiple services are provided
to the same taxpayer, guidelines direct TAC employees to record the
service they believe was the most significant.
This is usually based on the amount of time the employee spent assisting
the taxpayer with a specific service. The IRS version of the Q‑MATIC was not
designed to track delivery of multiple services.
The IRS advised us that, before it attempts to record and track delivery of multiple services, it is trying to focus on ensuring that the number of taxpayer contacts recorded is correct because this too has been an ongoing problem. The Field Assistance Office is exploring the possibility of using the Contact Recording System[20] to determine the number of different services the Centers provide. Until the IRS can accurately track all TAC services, it cannot accurately identify all TAC activity and determine employee workload–both of which are critical to the Evaluative Model.
Criteria contained inaccuracies involving the costs of resources
Criteria containing inaccurate data:
1.
Problem return coverage rate.
2.
Original count of Tax Year 2004 problem tax returns.
3.
Change in Tax Year 2004 problem tax return coverage rate if
eliminating a TAC.
4.
Reduction in problem tax return coverage rate for Processing
Year 2006* as a percentage of the target population if eliminating a TAC.
6.
TAC rent.
7.
Rentable/usable factor.
8.
Allocated technical Full-Time Equivalents (the number of hours
worked divided by the maximum number of compensable hours in a work year).
9.
On rolls.
10.
Other employees.
11.
Modernization efforts applied.
* The year in which tax returns and other tax data are processed.
For the most part, the 11 criteria we identified as having inaccurate data related to TAC real estate and employee costs. For example, the IRS inaccurately calculated rent costs, square footage, and the number of TAC employees currently on the payroll. We reported these same errors in Fiscal Year 2005, noting that this is typical information that any function should have readily available to operate effectively.[21]
Although the Field Assistance Office has implemented the Q-MATIC and the Field Assistance Management Information System to capture and process employee time‑reporting information and customer data, these systems still do not capture budget and/or operating costs by Center, including rent, personnel, and overhead. IRS attempts to capture these data to populate the Evaluative Model were unsuccessful. Without these data, the IRS cannot 1) accurately determine costs associated with the Centers, 2) determine the cost effectiveness or return on investment[22] for the TAC Program, or 3) make any decisions on which Centers to close.
Field Assistance Office officials stated they have a comprehensive communication strategy that has set clear expectations regarding the Office’s management information systems and how data are to be captured by the Centers. They advised us they have also issued formal guidance through official memoranda on the importance of capturing accurate information though the new Field Assistance Management Information System. Further, all Field Assistance Office managerial and executive performance plans include specific actions and expectations relative to data validation. Officials explained that specific actions include ongoing analysis and formal documented operations reviews to ensure accuracy of data related to customer interactions.
Prior recommendations
Our prior recommendations concerning the Field Assistance Office’s management information systems and the problems with inaccurate and unreliable data included 1) developing and implementing an information system that is based on reliable and accurate data and 2) capturing the number of taxpayers served, the numbers and types of services provided, and the related resources (costs). We also recommended the IRS develop a process that includes routine assessments of TAC operations to ensure that the Centers are optimally located and the services provided at the Centers are the most effective and cost efficient. Finally, the IRS should ensure that data used in any decision-making tool are accurate, reliable, and validated before using the data to make decisions regarding the TAC Program.
The IRS agreed to all of the recommendations previously discussed and has been working on corrective actions (particularly with the research efforts related to the Blueprint) and developing a new Field Assistance Office management information system. Because many of the concerns we identified in prior audits remain, we are making the same recommendations.
Recommendations
The Commissioner, Wage and Investment Division, should:
Recommendation 1: Improve the management information system to capture the number of taxpayers served, the numbers and types of services provided, and the related resources (costs).
Management’s Response: IRS management partially agreed with this recommendation. They will continue to capture data they are currently collecting because the data are sufficient to identify taxpayers’ needs and the services provided. They do not agree to capture detailed information regarding each individual service because it is cost and resource prohibitive. This recommendation would require a new, more robust tracking system to replace their current traffic management system. Aggressive actions have been taken to improve the Field Assistance Office’s management information systems to capture relevant data. They have engaged in a multi-tiered effort to review and validate data since the startup of the Field Assistance Management Information System in October 2007, which includes operational reviews and analysis of data. The Field Assistance Office captures taxpayers served and implemented management processes to ensure accuracy in the data through communication efforts, operational review processes, refinement of the data elements, and validation of data. The Real Estate and Facilities Management Office will validate the related resource costs of TAC operations.
Office of Audit Comment: Although the IRS did not agree to capture detailed information regarding each individual service taxpayers receive at the TACs because it is cost and resource prohibitive, it stated that information from the Contact Recording System, along with the Field Assistance Management Information System and Business Objects,[23] will be sufficient to capture taxpayer needs and services provided. We believe these systems together might provide sufficient information, and we will conduct followup testing during our planned Fiscal Year 2008 audit of the Field Assistance Management Information System.
Recommendation 2: Develop and implement an internal control system to ensure that management information data are accurate, reliable, and validated before using the data to make decisions regarding the TAC Program. This system should include a process to keep the data accurate and current.
Management’s Response: IRS management agreed with this recommendation. The Real Estate and Facilities Management Office will validate and certify the accuracy of information provided for all of its data elements. Updated information for the data elements will be provided to the Wage and Investment Division in May 2008. The TAC space assignment information will be provided subsequent to the ongoing TAC space validation process targeted for completion in July 2008. Because the Real Estate and Facilities Management Office information provided in support of the TAC Geographic Footprint is not static, the Office will provide continuous validated information for all data points on a quarterly basis beginning in the fourth quarter of Fiscal Year 2008. To ensure accurate and current data, the Field Assistance Office reviews and validates TAC data weekly by utilizing the Field Assistance Management Information System.
The Optimum Locations for the Taxpayer Assistance Centers and Which Taxpayers They Most Effectively Serve Have Not Been Determined
Although the IRS has begun extensive research to identify
taxpayers who have visited the Centers and who desire or need the face-to-face
services provided by them, Field Assistance Office management has not yet determined
which taxpayers the IRS can most effectively serve by its TAC Program. Without this, they cannot determine where to
locate the Centers.
The IRS has yet to identify which taxpayers are most effectively served by the TAC Program
To date, much of the IRS’ understanding of taxpayer needs, preferences, and behaviors is based on results of taxpayer responses to four surveys[24] reported in the Blueprint Phase 2 report. However, our review of the results of 1) the four surveys in the Blueprint report and 2) an additional survey–the Taxpayer Advocacy Panel survey[25]–showed that characteristics of taxpayers who use the services of a TAC varied among the five surveys. Figure 3 presents some of the varied taxpayer characteristics identified during our 1) review of the statements in the Blueprint Phase 2 report 2) review of the Taxpayer Customer Service and Channel Preference Survey 3) review of the Taxpayer Advocacy Panel Survey and 4) tests to determine the demographics of the approximately 1.6 million taxpayers who visited Centers for account assistance in Calendar Years 2004 and 2007.
Figure 3: Comparison of Taxpayer Characteristics
|
Source |
Income |
Language |
Age |
|
|
Blueprint Phase 2
Report |
Low-income
taxpayers tend to use TACs at a greater rate than the population at large. |
Limited-English-proficient
taxpayers tend to use TACs at a greater rate than the population at large. |
Elderly
taxpayers tend to use TACs at a greater rate than the population at large. |
|
|
Taxpayer Customer Service and Channel Preference Survey |
TAC user respondents had a mean income of $44,200. |
90% of TAC user respondents listed English as their primary
language. |
81% of TAC user respondents were under age 65. |
|
|
Taxpayer Advocacy
Panel Survey |
56% of TAC user respondents had income of less than $35,000. |
72% of TAC user respondents listed English as their primary
language. |
85% of TAC user respondents were under age 65. |
|
|
TIGTA Analysis of Taxpayers Who Visited |
Calendar Year 2004 |
The average income of taxpayers was $50,983. |
|
The average age of taxpayers was |
|
TACs for Account Assistance |
Calendar Year 2007 |
The average income of taxpayers was $56,211. |
|
The average age of taxpayers was |
Source: The 2007 Blueprint Phase 2 report, Taxpayer Customer Service and Channel Preference Survey results, Taxpayer Advocacy Panel Survey results, and our analysis.
In March 2006, we reported the results of tests to determine the accuracy of the data in the TAC Closure Model, stating the IRS has available for its use taxpayer account data that could be used to better identify the characteristics of customers who have sought or may seek account assistance at a Center.[26] However, the IRS did not include these data when developing the Blueprint Phase 2 report.
Instead, the IRS analyzed problem tax returns[27] and included these data in the Evaluative Model criteria. Taxpayers with problem tax returns are certainly potential customers of the Centers. Nevertheless, the IRS has account data for those taxpayers who in fact visited Centers and should include these data when trying to determine the demographics of TAC customers. More than 3 million (46 percent) of the taxpayer contacts for account assistance in Fiscal Year 2007 were made at TACs.[28] Figure 4 presents a breakdown of TAC contacts for the last 4 fiscal years.
Figure 4: Contacts[29] at the TACs for
Fiscal Years 2004 – 2007 (in millions)[30]
Figure 4 was removed due to its size. To see Figure 4, please go to the Adobe PDF
version of the report on the TIGTA Public Web Page.
The Blueprint
represents the IRS’ first large-scale attempt to collect data specific to
TAC customers. However, as the IRS recognizes,
the survey results do not clearly distinguish between TAC users and non-TAC users to enable it to effectively
draw conclusions about the characteristics of individuals who use the services
of a Center. The IRS plans to continue
to conduct surveys in Fiscal Year 2008. It
must continue to develop data about which customers are best served by the TAC
Program to develop and deliver an effective customer service strategy.
The IRS has yet to develop a process to identify the optimal TAC locations
In July 2005, we reported that there are no current data to support why the Centers are in their present locations.[31] They are in the same locations as when the Field Assistance Office took ownership of the TAC Program in October 2000. Since the Field Assistance Office took ownership, the IRS has developed two separate models but has been unable to finalize or use any model to evaluate Center locations.
The Office of Program Evaluation and Risk Analysis has developed a dynamic program called the Geographic Coverage Rate Model (included as part of the Evaluative Model) that can be used to better identify the optimal Center locations.[32] The Geographic Coverage Rate Model measures the proportion of a specified population that is within a given travel time of the nearest Center. The Geographic Coverage Rate Model can be used to determine the locations that yield the maximum coverage rate for a given population. For example, if the IRS determines which individuals it can most effectively serve, the characteristics of these individuals can be input to the Geographic Coverage Rate Model. This Model will identify, by zip code, the locations at which the Centers would provide maximum coverage to these specific taxpayers.
The Geographic Coverage Rate Model is particularly important because 119 (30 percent) of the 401 TAC leases expire in Fiscal Years 2008 and 2009. This Model could be used to determine, for a Center whose lease is expiring, if the current location is best and/or identify a better one. However, Field Assistance Office management has not yet determined which taxpayers the IRS can most effectively serve by its TAC Program. Without this, they cannot determine where to best locate the Centers.
Field Assistance Office officials advised us that based on the availability of Office data, a Geographic Coverage Initiative was recently launched. The initiative is designed to use specifically focused information to develop a repeatable process that can be used by the Office to help ensure TAC coverage for service delivery.
Recommendation
The Commissioner, Wage and Investment Division, should:
Recommendation 3: Develop a process that includes routine assessments of TAC operations to ensure that the TACs are optimally located and the services provided at the TACs are the most effective and cost efficient. Use of the Geographic Coverage Rate Model should be included in this process.
Management’s Response: IRS management agreed with this recommendation. The Field Assistance Office will use the process developed by the Geographic Coverage Initiative to create a balanced footprint designed to maximize taxpayer needs and services provided. The Field Assistance Office will implement this process during the quarterly assessment of taxpayer and Federal Government value criteria.
The Internal Revenue Service Is Unable to Measure How Closing Taxpayer Assistance Centers Might Affect Taxpayers and Compliance
In March 2006, we reported[33] that the IRS could not determine the effect that Center closures might have on taxpayer compliance. The IRS did not have the means to capture all interactions between a TAC employee and a taxpayer to determine why the taxpayer visited a Center, what service he or she received, and–most importantly–the effect the service or action has on the taxpayer’s future compliance. In addition, although the IRS had management information to determine to some degree which taxpayers visit the Centers, the information was not always reliable.
Congress continues to remain concerned about the effect of Center closures on taxpayers. In a Senate Report on the 2008 Budget,[34] the Senate Committee on Appropriations cited concerns about any IRS efforts to significantly reduce taxpayer services, including face-to-face services. The Committee directed that, if the IRS proposes further reductions in taxpayer services that involve a decrease in face-to-face service, the IRS must demonstrate that the proposed reductions do not adversely affect compliance by taxpayers.
Although the IRS has conducted and is conducting a significant number of surveys and research, it still does not capture all interactions between TAC employees and taxpayers and still does not have reliable management information with which to determine all the reasons why taxpayers visit the Centers. Until its new TAC management information system is completely installed and all services are counted, the IRS will be unable to determine this. Additionally, the IRS still does not have management information systems to determine the downstream effect of the services on taxpayer compliance.
The IRS is not planning to conduct specific projects that assess the impact on compliance when closing Centers. However, research projects are planned for Fiscal Years 2008 and 2009 to determine the impact of taxpayer service on compliance, including the services provided at a Center. We are making no recommendations at this time and will continue to monitor IRS efforts in this area.
Appendix
I
Detailed Objective, Scope, and Methodology
Our overall objective was to assess the accuracy and
completeness of the data compiled for use in the IRS’
I. Determined if the IRS has data detailing the characteristics of individuals who use the services of a Center.
A. Discussed with responsible IRS officials the efforts taken to identify characteristics of individuals who use the services of a Center.
B. Reviewed the Taxpayer Assistance Blueprint (Blueprint) Phase 2 report to identify efforts taken to identify characteristics of individuals who use the services of a Center.
C. Assessed the accuracy and completeness of this information by analyzing results of the four surveys conducted and included in the Blueprint Phase 2 report.
D. Attempted to determine the effect on the TAC Assessment process by determining what types of taxpayers visited a Center during Fiscal Year 2007 with questions concerning their accounts.
II. Assessed the accuracy of data used to populate the Geographic Coverage Rate Model.[35]
A. Discussed with responsible individuals in the Office of Program Evaluation and Risk Analysis the data and methodology used to develop the Geographic Coverage Rate Model, including the process followed to verify the accuracy of the resulting data.
B. Assessed the accuracy of computer programs written to perform calculations to populate the Geographic Coverage Rate Model.
C. Assessed the accuracy of the data used to populate the Geographic Coverage Rate Model.
D. For any inaccuracies, attempted to determine the effect on the TAC Assessment process.
III. Assessed the accuracy of the data used to populate the Evaluative Model.[36]
A. Discussed with responsible individuals in the Taxpayer Services Program Management office the data obtained, as well as the process for verifying the data used, to populate the Evaluative Model.
B. For each of the 41 criteria included in the Evaluative Model, assessed the accuracy of the data used to populate the Model for the 60 TACs that were reviewed during our prior audit.
C. For any inaccuracies, attempted to determine the effect on the TAC Assessment process.
IV. Determined if the IRS has in place or planned a process to assess the impact on voluntary compliance of closing any Centers.
A. Discussed with responsible individuals the process by which the IRS will measure the impact on voluntary compliance if the IRS decides to close Centers.
B. Assessed the accuracy and completeness of this information.
Appendix II
Major Contributors to This Report
Michael E. McKenney, Assistant Inspector General for Audit (Wage and
Investment Income Programs)
Augusta R. Cook, Director
Russell P. Martin, Audit Manager
Pamela DeSimone, Senior Auditor
Lynn Faulkner, Senior Auditor
Kathleen Coote, Auditor
Mary Keyes, Auditor
Joseph Butler, Information
Technology Specialist
Appendix III
Commissioner C
Office of the Commissioner – Attn: Chief of Staff C
Deputy Commissioner for Operations Support OS
Deputy Commissioner for Services and Enforcement SE
Deputy, Commissioner, Wage and Investment Division SE:W
Chief, Agency-Wide Shared Services OS:A
Director, Office of Research, Analysis, and Statistics RAS
Director, Office of Program Evaluation and Risk
Analysis RAS:O
Director, Customer Assistance, Relationships, and
Education, Wage and Investment Division
SE:W:CAR
Director, Strategy and Finance, Wage and Investment
Division SE:W:S
Director,
Taxpayer Services Performance Management Office, Wage and Investment Division SE:W:TSPMO
Chief
Counsel CC
National
Taxpayer Advocate TA
Director, Office of Legislative Affairs CL:LA
Office of Internal Control
OS:CFO:CPIC:IC
Audit Liaison:
Chief, Performance Improvement, Wage and Investment Division SE:W:S:P
Appendix IV
Treasury Inspector General for Tax Administration Audit
Reports
·
Trends in Customer Service in the Taxpayer Assistance
Centers Continue to Show Procedural Causes for Inaccurate Answers to Tax Law
Questions (Reference Number
2003-40-158, dated August 2003).
·
The
Effectiveness of the
·
Taxpayer Service Is Improving, but Challenges Continue
in Meeting Expectations (Reference
Number 2006-40-052, dated February 2006).
·
The
Appendix V
Taxpayer and Federal Government
Taxpayer Assistance Center Evaluation Criteria
|
Taxpayer Criteria |
Explanation |
|
|
1 |
Total
population coverage rate. |
Percentage
of population, by zip code, located within 30 minutes of travel time from a TAC.
|
|
2 |
Low-income
tax return coverage rate (adjusted gross income less than $36,000). |
Percentage
of low-income (based on $36,000) tax return filing population, by zip code,
located within 30 minutes of travel time from a TAC. |
|
3 |
Low-income
tax return coverage rate (Earned Income Tax Credit cutoff for Processing Year[37]
2006 = $35,263). |
Percentage
of low-income (based on $35,263) tax return filing population, by zip code,
located within 30 minutes of travel time from a TAC. |
|
4 |
Problem
return[38]
coverage rate. |
Percentage
of potentially noncompliant tax return population, by zip code, located
within 30 minutes of travel time from a TAC. |
|
5 |
Total
Processing Year 2006 individual tax return coverage rate. |
Percentage
of total Processing Year 2006 individual tax return population, by zip code,
located within 30 minutes of travel time from a TAC. |
|
6 |
Low-education
tax return coverage rate. |
Percentage
of low-education (less than high school) population, by zip code, located
within |
|
7 |
Wage
and Investment Division total tax return coverage rate |
Remove
the TAC from geographic coverage analysis and recalculate overall TAC
coverage for total population. |
|
8 |
Change
in overall total Processing Year 2006 coverage rate if eliminating a TAC. |
Remove
the TAC from geographic coverage analysis and recalculate overall TAC
coverage for total Processing Year 2006 tax returns. |
|
9 |
Change
in overall low-income tax return coverage rate if eliminating a TAC. |
Remove
the TAC from geographic coverage analysis and recalculate overall TAC
coverage for low-income tax returns. |
|
10 |
Change
in overall Wage and Investment Division low-income total tax return coverage
rate if eliminating a TAC. |
Remove
the TAC from geographic coverage analysis and recalculate overall TAC
coverage for low-income tax returns. |
|
11 |
Change
in overall low-education tax return coverage rate if eliminating a TAC. |
Remove
the TAC from geographic coverage analysis and recalculate overall TAC
coverage for low-education population. |
|
12 |
Original
count of Tax Year 2004 problem tax returns. |
Count
by zip code of the number of Tax |
|
13 |
Change in Tax Year 2004 problem tax return coverage rate if
eliminating a TAC. |
Remove
the TAC from geographic coverage analysis and recalculate overall TAC
coverage for potentially noncompliant tax returns. |
|
14 |
Reduction
in total population coverage rate as a percentage of the target population if
eliminating a TAC. |
Remove
the TAC from geographic coverage analysis and recalculate overall TAC
coverage for total population. |
|
15 |
Reduction
in problem tax return coverage rate for Processing |
Remove
the TAC from geographic coverage analysis and recalculate overall TAC
coverage for potentially noncompliant tax returns. |
|
16 |
Reduction
in low-income tax return coverage rate as a percentage of the target
population if eliminating a TAC. |
Remove
the TAC from geographic coverage analysis and recalculate overall TAC
coverage for low-income population. |
|
17 |
Proximity
of next closest TAC (travel time in minutes). |
Distance
to next closest TAC (travel time in minutes). |
|
18 |
Next
closest TAC name/building code. |
Closest
TAC name and building code. |
|
19 |
Capacity
of alternate TAC to absorb displaced volume count/percentage. |
The
nearest TAC site(s) having the requisite capacity to absorb the total volume
estimated to be migrated from a given TAC. |
|
Government
Criteria |
Explanation |
||
|
1 |
Lease/own. |
TAC space is leased or owned by the Federal Government. |
|
|
2 |
Lease expiration. |
Lease expiration date. |
|
|
3** |
TAC square feet. |
Total square footage. |
|
|
4** |
TAC rent. |
Annual rent expenditure. |
|
|
5** |
Rentable/usable factor. |
Rentable space is the area for which a tenant is charged
rent. Usable space is computed by
measuring the area enclosed by the finished surface of the room side of
corridors and other permanent walls. Rentable/usable
factor is computed by dividing the rentable space by the usable space. |
|
|
6 |
Cost per square foot. |
Rent cost per square foot. |
|
|
7 |
TAC size. |
Defined
as small, medium, or large based on the number of technical employees at the
TAC. |
|
|
8 |
Standalone TAC (yes or no). |
The TAC is the only IRS function
in the building. |
|
|
9** |
Allocated technical Full-Time Equivalents (the number of hours worked divided by the maximum number
of compensable hours in a work year). |
Number of Full-Time Equivalent employees allocated to a
given TAC in the Field Assistance Office’s allocated staffing plan. |
|
|
10** |
On rolls. |
Number of employees currently employed in a TAC (as of
Fiscal Year 2007). |
|
|
11 |
Initial assistance representatives. |
Number of initial assistance representatives currently employed
in a TAC. |
|
|
12** |
Other employees. |
Number of other employees (e.g., secretaries, supervisors,
clerks) currently employed in a TAC. |
|
|
13 |
Technical. |
Number of technical employees currently employed in a TAC. |
|
|
14 |
Retirement eligibility. |
Number of employees eligible for
retirement by the estimated TAC closure date. |
|
|
15* |
Total volume per Business
Performance Management System. |
Total number of contacts delivered in
a given TAC during last full fiscal year. |
|
|
16* |
Total volume per Q-Matic.[39] |
Total number of contacts delivered in a given |
||
|
17* |
Total contacts potentially deliverable via IRS.gov. |
Total contacts delivered by a given TAC during last full fiscal
year that could be delivered via IRS.gov. |
||
|
18* |
Percentage of total volume potentially deliverable via
IRS.gov. |
Percentage of TAC contacts delivered by a given TAC during
last full fiscal year that could be delivered via IRS.gov. |
||
|
19* |
Total technical and initial assistance representative
program hours expressed in Full-Time Equivalents. |
Technical and initial assistance representative program
hours divided by the number of staff hours that represent a Full-Time Equivalent. |
||
|
20* |
Potential IRS.gov contacts per technical Full-Time Equivalent. |
Total contacts delivered by a given TAC during last full fiscal
year that could be delivered via IRS.gov expressed as Full-Time Equivalents. |
||
|
21* |
Total filing season[40] volume per
Business Performance Management System. |
Total number of contacts delivered in a given TAC during a filing
season. |
||
|
22** |
Modernization efforts applied. |
Have investments already been made in installing the TAC
Model Design[41] in the given TAC
(if TAC is moving, ignore this criterion). |
||
Source: IRS Evaluative Model as of October 2007.
* One of the eight criteria the IRS determined contained inaccurate data.
** One of the 11 criteria we determined contained inaccurate or incomplete data.
Appendix VI
Management’s Response to the Draft Report
The response was removed due to its
size. To see the response, please go to
the Adobe PDF version of the report on the TIGTA Public Web Page.
[1] H.R. 3058, Transportation,
Treasury, Housing and Urban Development, the Judiciary, the
[2] Senate Report 109‑109 - Transportation, Treasury, Housing and Urban Development, the Judiciary, the District of Columbia, and Independent Agencies Appropriations Act, 2006.
[3] The Field Assistance Office is responsible for the TAC Program.
[4]
The
Effectiveness of the
[5] The net profit or loss in an accounting period divided by the capital investment used during the period, usually expressed as an annual percentage return.
[6]
The Taxpayer Customer Service and Channel
Preference Survey, the Taxpayer Assistance Blueprint Conjoint II Study, the Opinion
Survey of Taxpayer Resources and Services, and the 2006 Wage and Investment
Division Market Segment Survey, which were all conducted during Calendar Year
2006.
[7] The Contact Recording System captures the audio portion of the employee/customer interaction. It is synchronized with computer screen activity for replay and quality review.
[8] Business Objects software provides the IRS the capability to identify total contacts, wait time, and employee time utilization.
[9] H.R.
3058, Transportation, Treasury, Housing and Urban Development, the Judiciary,
the
[10] Senate
Report 109‑109 - Transportation, Treasury, Housing and Urban Development,
the Judiciary, the
[11] Transportation, Treasury, Housing and Urban Development, the Judiciary, the District of Columbia, and Independent Agencies Appropriations Act, 2006, Pub. L. No. 109-115, 119 Stat. 2396 (2005).
[12] The IRS Commissioner chartered the Services Committee as the governance body for IRS service investment decisions. The committee is responsible for overseeing, prioritizing, and approving an integrated portfolio of IRS services.
[13] The period from January through mid-April when most individual income tax returns are filed.
[14] See Appendix IV for a list of the audit reports referred to in Figure 2.
[15] See Appendix V for a list of the 41 criteria.
[16] GAO/AIMD-00-21.3.1, dated November 1999.
[17] Criteria: Total volume per Business Performance Management System, Total volume per Q-Matic, and Total filing season volume per Business Performance Management System.
[18] Criteria: Total contacts potentially deliverable via IRS.gov, Percentage of total volume potentially deliverable via IRS.gov, and Potential IRS.gov contacts per technical Full-Time Equivalent.
[19]
The Effectiveness of the Taxpayer Assistance
Center Program Cannot Be Measured (Reference Number 2005‑40‑110,
dated July 2005).
[20] The Contact Recording System captures the audio
portion of the employee/customer interaction.
It is synchronized with computer screen activity for replay and quality
review.
[21] See Appendix V for detailed definitions of each of the criteria.
[22] The net profit or loss in an accounting period divided by the capital investment used during the period, usually expressed as an annual percentage return.
[23] Business Objects software provides the IRS the capability to identify total contacts, wait time, and employee time utilization.
[24] The Taxpayer Customer Service and Channel Preference
Survey, the Taxpayer Assistance Blueprint Conjoint II Study, the Opinion Survey
of Taxpayer Resources and Services, and the 2006 Wage and Investment Division
Market Segment Survey, which were all conducted during Calendar Year 2006.
[25] The Taxpayer Advocacy Panel Survey was conducted in
February, March, and May 2007. Thirty
offices were visited, and more than 1,100 taxpayers responded to the
survey.
[26] The
[27] Defined by the IRS as tax returns filed late or not fully paid.
[28] For Fiscal Year 2007, the IRS changed the way it counted contacts. It counted the number of services provided rather than the number of taxpayers served.
[29] Other Contacts include assisting taxpayers that call the TACs, date-stamping tax returns brought in by taxpayers, helping taxpayers with general information such as addresses and directions to other IRS offices or other Federal Government agencies, and responding to unsolicited correspondence.
[30]
The Field Assistance Office’s management
information system is incomplete and inaccurate; however, it is the best data
available.
[31] The Effectiveness of the
[32] Representatives from the Office of Program Evaluation and Risk Analysis performed an extensive quality review of the programming used in the Geographic Coverage Rate Model.
[33] The
[34] H.R. 2829 - Financial Services and General Government Appropriations Act for Fiscal Year 2008, Division D.
[35] The Geographic Coverage Rate Model measures the proportion of a specified target population that is within a given travel time of the nearest TAC. It can be used to determine the locations that yield the maximum coverage rate for a given population.
[36] The current Evaluative Model was built as part of the Blueprint initiative to develop a service delivery plan and establish a Geographic Footprint for the TAC Program.
[37] The year in which tax returns and other tax data are processed.
[38] Defined by the IRS as tax returns filed late or not fully paid.
[39] An automated queuing system used to control the flow of taxpayers waiting for assistance. In most TACs, the Q‑MATIC automatically records the number of taxpayers assisted.
[40] The period from January through mid-April when most individual income tax returns are filed.
[41] TAC Model Design established detailed requirements for small, medium, and large TACs. The TAC Model Design Guide will be used as a planning and implementation tool by field facility offices to solicit appropriate leased space for new or relocated TACs nationwide.