TREASURY INSPECTOR GENERAL FOR TAX ADMINISTRATION

 

 

Fiscal Year 2011 Statutory Audit of Compliance With Legal Guidelines Prohibiting the Use of Illegal Tax Protester and Similar Designations

 

 

 

April 29, 2011

 

Reference Number:  2011-30-040

 

 

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.

 

Redaction Legend:

1 = Tax Return/Return Information

 

Phone Number   |  202-622-6500

Email Address   |  TIGTACommunications@tigta.treas.gov

Web Site           |  http://www.tigta.gov

 

 

HIGHLIGHTS

 

FISCAL YEAR 2011 STATUTORY AUDIT OF COMPLIANCE WITH LEGAL GUIDELINES PROHIBITING THE USE OF ILLEGAL TAX PROTESTER AND SIMILAR DESIGNATIONS

 

Highlights

Final Report issued on April 29, 2011

Highlights of Reference Number:  2011-30-040 to the Internal Revenue Service Deputy Commissioner for Services and Enforcement and Deputy Commissioner for Operations Support.

IMPACT ON TAXPAYERS

Congress enacted Internal Revenue Service (IRS) Restructuring and Reform Act of 1998 (RRA 98) Section 3707 to prohibit the IRS from labeling taxpayers as Illegal Tax Protesters or any similar designations.  However, IRS employees continue to refer to taxpayers by these designations in case narratives.  Using Illegal Tax Protester or other similar designations may stigmatize taxpayers and may cause employee bias in future contacts with these taxpayers.

WHY TIGTA DID THE AUDIT

This audit was initiated because TIGTA is required to annually evaluate compliance with the prohibition against using Illegal Tax Protester or similar designations.  Prior to enactment of the RRA 98, the IRS used the Illegal Tax Protester Program to identify individuals and businesses using methods that were not legally valid to protest the tax laws.  IRS employees referred taxpayers to the Illegal Tax Protester Program when their returns or correspondence contained specific indicators of noncompliance with the tax law, such as the use of arguments that had been repeatedly rejected by the courts.

Congress enacted the prohibition against Illegal Tax Protester designations because it was concerned that some taxpayers were being permanently labeled as Illegal Tax Protesters even though they had subsequently become compliant with the tax laws.  The label could bias IRS employees and result in unfair treatment.  The purpose of our audit was to determine whether the IRS complied with RRA 98 Section 3707 and internal guidelines that prohibit officers and employees from referring to taxpayers as Illegal Tax Protesters and similar designations.

WHAT TIGTA FOUND

The IRS has not reintroduced past Illegal Tax Protester codes or similar designations on taxpayer accounts.  In addition, the Internal Revenue Manual no longer contains any Illegal Tax Protester references.  However, TIGTA found that out of approximately 3.6 million records and cases, there were 38 instances in which 34 employees had referred to taxpayers as “Tax Protester,” “Constitutionally Challenged,” or other similar designations in case narratives on the computer systems analyzed.

WHAT TIGTA RECOMMENDED

TIGTA made no new recommendations in this report because the IRS has long disagreed with our determination that in order to comply with RRA 98 Section 3707, IRS employees should not designate taxpayers as Illegal Tax Protesters or similar designations in case histories.  Moreover, TIGTA has previously elevated this disagreement to the Assistant Secretary for Management and Chief Financial Officer of the Department of the Treasury, but it has yet to be resolved. 

Although TIGTA made no recommendations in this report, IRS officials were provided an opportunity to review the draft report.  IRS management did not provide any report comments. 

 

April 29, 2011

 

 

MEMORANDUM FOR DEPUTY COMMISSIONER FOR SERVICES AND ENFORCEMENT

                                         DEPUTY COMMISSIONER FOR OPERATIONS SUPPORT

 

FROM:                            Michael R. Phillips /s/ Michael R. Phillips

                                         Deputy Inspector General for Audit

 

SUBJECT:                    Final Audit Report – Fiscal Year 2011 Statutory Audit of Compliance With Legal Guidelines Prohibiting the Use of Illegal Tax Protester and Similar Designations (Audit # 201030044)

 

This report presents the results of our review to determine whether the Internal Revenue Service (IRS) complied with the IRS Restructuring and Reform Act of 1998[1] Section 3707 and its own internal guidelines that prohibit IRS officers and employees from referring to taxpayers as Illegal Tax Protesters or any similar designations.  The Treasury Inspector General for Tax Administration is required under Internal Revenue Code Section 7803(d)(1)(A)(v) to annually evaluate the IRS’s compliance with the provisions of the IRS Restructuring and Reform Act of 1998 Section 3707.

Although we made no recommendations in this report, we did provide IRS officials an opportunity to review the draft report.  IRS management did not provide us with any report comments.

Copies of this report are also being sent to the IRS managers affected by the report.  Please contact me at (202) 622-6510 if you have questions or Margaret E. Begg, Assistant Inspector General for Audit (Compliance and Enforcement Operations), at (202) 622-8510.

 

 

Table of Contents

 

Background

Results of Review

Illegal Tax Protester Codes Were Not Used on the Master File

Illegal Tax Protester References Have Been Removed From the Internal Revenue Manual

In Some Instances, Employees Used Illegal Tax Protester or Similar Designations in Case Narratives

Alternative Methods That Avoid the Need for Illegal Tax Protester Designations Have Been Established to Address Tax Compliance Issues

Appendices

Appendix I – Detailed Objective, Scope, and Methodology

Appendix II – Major Contributors to This Report

Appendix III – Report Distribution List

Appendix IV – Outcome Measure

Appendix V – Glossary of Terms

 

 

Abbreviations

 

IRM

Internal Revenue Manual

IRS

Internal Revenue Service

RRA 98

Restructuring and Reform Act of 1998

TIGTA

Treasury Inspector General for Tax Administration

 

 

Background

 

Internal Revenue Service (IRS) Restructuring and Reform Act of 1998 (RRA 98)[2] Section (§) 3707 prohibits the IRS from using Illegal Tax Protester or any similar designations.  In addition, the law requires the removal of all existing Illegal Tax Protester codes from the Master File[3] and instructs IRS employees to disregard any such designation not located on the Individual Master File.

Prior to enactment of the RRA 98, the IRS used the Illegal Tax Protester Program to identify individuals and businesses that were using methods that were not legally valid to protest the tax laws.  Employees identified taxpayers for referral to the Program when their tax returns or correspondence contained specific indicators of noncompliance with the tax law, such as the use of arguments that had been repeatedly rejected by the courts.  There were tax protester coordinators who were responsible for determining whether a taxpayer should be included in the Illegal Tax Protester Program.  If a taxpayer was classified as an Illegal Tax Protester, the taxpayer’s record was coded as such on the Master File.  Once a taxpayer’s account was coded, certain tax enforcement actions were accelerated.  The designation was also intended to alert employees to be cautious so they would not be drawn into confrontations with taxpayers.

Congress was concerned that some taxpayers were being permanently labeled and stigmatized by the Illegal Tax Protester designation.  The concern was that this label could bias IRS employees and result in unfair treatment of the taxpayer.

The TIGTA is required to annually evaluate IRS compliance with the prohibition against using Illegal Tax Protester or any similar designations.

Internal Revenue Code § 7803(d)(1)(A)(v) requires the Treasury Inspector General for Tax Administration (TIGTA) to annually evaluate IRS compliance with the prohibition against using the Illegal Tax Protester or any similar designations.  This is our thirteenth review since Fiscal Year 1999.  These reviews have identified areas for improvement to help the IRS comply with the Illegal Tax Protester designation prohibition.

This review was performed in the Office of the National Taxpayer Advocate and Office of Appeals in Washington, D.C.; the Small Business/Self-Employed Division’s Campus Compliance Services and Collection functions in Lanham, Maryland; and the Wage and Investment Division’s Compliance function in Atlanta, Georgia, during the period July 2010 through January 2011.  We conducted this performance audit in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objective.  We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objective.  Detailed information on our audit objective, scope, and methodology is presented in Appendix I.  Major contributors to the report are listed in Appendix II.

 

 

Results of Review

 

The TIGTA made no new recommendations in this report because the IRS has long disagreed with our determination that in order to comply with RRA 98 § 3707, IRS employees should not designate taxpayers as Illegal Tax Protesters or similar designations in case histories.  Moreover, the TIGTA has previously elevated this disagreement to the Assistant Secretary for Management and Chief Financial Officer of the Department of the Treasury, but it has yet to be resolved.

Based on the steady decline in the use of Illegal Tax Protester or similar designations by IRS employees in recent years, and in the interest of conserving resources, we revised our methodology for evaluating the use of these designations on the multiple computer systems used by IRS employees.  We will continue to review the Individual Master File and related systems annually and will review other IRS systems on a periodic basis.  The scope of our review for this year is shown in Appendix I.

Illegal Tax Protester Codes Were Not Used on the Master File

Prior to enactment of the RRA 98, the IRS used Illegal Tax Protester indicators on the Master File to accelerate collection activity for taxpayers who were delinquent in filing tax returns or paying their taxes.  These indicators were also intended to alert employees that they might encounter problems when dealing with nonfilers and delinquent taxpayers.

Congress was concerned about the use of the Illegal Tax Protester designation because:

RRA 98 § 3707 required the IRS to remove the existing Illegal Tax Protester designations from taxpayers’ accounts on the Master File beginning January 1, 1999.

In prior reviews, we reported the IRS had removed these designation codes from the Master File as required by the law.  Based on our analysis of approximately 1.2 million taxpayer records that had been coded for accelerated collection activity, the IRS has not reintroduced Illegal Tax Protester codes on the Master File.  The law also prohibits using any designation similar to Illegal Tax Protester.  We matched approximately 57,000 taxpayer accounts formerly coded as Illegal Tax Protesters to the Master File and confirmed that the IRS had not input any other type of similar designation on these accounts.

Illegal Tax Protester References Have Been Removed From the Internal Revenue Manual

The picture was removed due to its size.  To see the picture, please go to the Adobe PDF version of the report on the TIGTA Public Web Page.

In 9 of our 12 prior reviews, we identified Illegal Tax Protester references in various formats of the Internal Revenue Manual (IRM).  The official IRM is maintained on the Electronic Publishing web site.  However, it is also found electronically on the IRM Online, the Servicewide Electronic Research Program, IRS.gov, and on CD-ROM, as well as in paper format.  The graphic to the right shows the relationship between the Official IRM and the various formats available to IRS employees.

During our Fiscal Year 2011 review, we again verified that no Illegal Tax Protester references existed in the IRM.  By removing all Illegal Tax Protester references from the IRM, the IRS avoids any inappropriate implication to taxpayers for whom these designations are being used.

In Some Instances, Employees Used Illegal Tax Protester or Similar Designations in Case Narratives

During the period October 2009 through September 2010, we found 38 instances, out of approximately 3.6 million records and cases, in which 34 employees had labeled taxpayers as “Tax Protester,” “Constitutionally Challenged,” or other similar designations in case narratives on the following computer systems:

We believe the 38 instances identified in the systems previously listed are prohibited by law.  Figure 1 contains the number of Illegal Tax Protester or similar designations identified in IRS computer systems’ case narratives during our Fiscal Years 2010 and 2011 reviews.

Figure 1:  Illegal Tax Protester and Similar Designations in Case Narratives

Computer System

Fiscal Year 2010 Review

Fiscal Year 2011 Review

Employees Involved

Protester Designation Used

Similar Designation Used

Employees Involved

Protester Designation Used

Similar Designation Used

Appeals Centralized Database System

19

**1**

**1**

33

**1**

**1**

Taxpayer
Information File

1

**1**

**1**

1

**1**

**1**

Source:  Case narratives found on various IRS computer systems and the TIGTA report entitled Fiscal Year 2010 Statutory Audit of Compliance With Legal Guidelines Prohibiting the Use of Illegal Tax Protester and Similar Designations (Reference Number 2010-30-073, dated July 23, 2010).

We also identified 13 case narratives in which employees made references about the taxpayers’ actions (e.g., *******1*************** ************************1*************************** We agree with the IRS that merely making references to a taxpayer’s actions does not constitute a designation prohibited by statute.  However, we are concerned these references could become, or be considered, permanent labels that could subsequently stigmatize taxpayers in future contacts with the IRS.  We did not include any instances in which employees were only documenting statements made by a taxpayer and/or his or her representative because quoting a taxpayer’s self-designation as an Illegal Tax Protester is not prohibited by the law.

The statute states that “officers and employees of the Internal Revenue Service shall not designate taxpayers as Illegal Tax Protesters (or any similar designation).”  It further specifies that existing designations in the Master File must be removed and any other designations made before the effective date of the statute, such as those on paper records that have been archived, must be disregarded.  Senate Committee on Finance Report 105-174 (dated April 22, 1998), related to the RRA 98 § 3707 provision, stated the Committee was concerned that taxpayers might be stigmatized by a designation as an “Illegal Tax Protester.”  Based upon the language of the statute and the Senate Committee Report, we believe IRS officers and employees should not label taxpayers as Illegal Tax Protesters or similar designations in any records, which include paper and electronic case files.  Officers and employees should not designate taxpayers as such because a designation alone contains a negative connotation and appears to label the taxpayer.  

IRS management disagrees that employee use of Illegal Tax Protester or similar designations in a case narrative is a potential violation of the law.  We continue to believe that the use of these designations in case narratives may stigmatize taxpayers and cause employee bias in future contacts with these taxpayers.  Electronic case narratives are available to other IRS employees for future reference and may affect the opinions and actions of employees working the taxpayers’ cases.

In its response to our Fiscal Year 2003 report,[4] the IRS disagreed with our determination that in order to comply with this provision, IRS employees should not designate taxpayers as Illegal Tax Protesters or similar designations in case histories.  As a result, we elevated this disagreement to the Assistant Secretary for Management and Chief Financial Officer of the Department of the Treasury, but have not yet received a response.  Even though IRS management continues to disagree with our interpretation of the law, they have taken a conservative approach by implementing a policy that prohibits employees from using Illegal Tax Protester or any similar designation.  In August 2007, IRS management issued a memorandum to all employees reminding them of this policy.  In Fiscal Year 2008, guidance in the form of Alerts and memorandums were issued to employees, and portions of the IRM were updated to reflect the prohibition on using Illegal Tax Protester or any similar designation.  IRS management still continues to reinforce its policy by issuing Alerts and ensuring that IRM updates retain reminders to employees regarding the prohibition on the use of Illegal Tax Protester or similar designations.  

Alternative Methods That Avoid the Need for Illegal Tax Protester Designations Have Been Established to Address Tax Compliance Issues

IRS tax compliance operations have not been significantly affected by the prohibition against using Illegal Tax Protester or similar designations because alternative programs exist to address issues previously handled by the Illegal Tax Protester Program.  These include:

Each of these programs is set up to address various issues IRS employees may encounter when dealing with taxpayers protesting the legality of paying their income taxes.  Unlike the former Illegal Tax Protester Program, each program addresses a specific taxpayer behavior.  In addition, taxpayers are not assigned to these individual programs on a permanent basis, as was the case in the Illegal Tax Protester Program.

None of our prior reviews have identified instances in which the Illegal Tax Protester indicator was needed on a taxpayer’s account to either accelerate tax enforcement actions and/or alert IRS employees to be cautious when dealing with the taxpayer.  As a result, we believe that prohibiting the use of the Illegal Tax Protester designation has had no negative impact on collection or examination activities.

 

Appendix I

 

Detailed Objective, Scope, and Methodology

 

The objective of this review was to determine whether the IRS complied with RRA 98[5] Section (§) 3707 and its own internal guidelines that prohibit IRS officers and employees from referring to taxpayers as Illegal Tax Protesters or any similar designations.  The TIGTA is required to annually evaluate compliance with the prohibition against using Illegal Tax Protester or any similar designations.  Unless otherwise noted, our limited tests of the reliability of data obtained from various IRS systems did not identify any errors.  We tested the reliability of the data by scanning the data received for blank, incomplete, illogical, or improper data.  In addition, we traced a judgmental sample for each data set to the source IRS files to ensure accuracy.  To accomplish the objective, we:

I.                   Determined if the Illegal Tax Protester coding on the Master File[6] was removed by reviewing all tax accounts coded for accelerated collection activity as of September 2010 on the Business Master File and Individual Master File.  We analyzed 1,220,355 Master File records that had been coded for accelerated collection activity.[7]

We also matched our historic computer extract of approximately 57,000 taxpayers designated as Illegal Tax Protesters before the RRA 98 was enacted to our records that had been coded for accelerated collection activity to determine if any new common codes were being used to classify the taxpayers as Illegal Tax Protesters.

II.                Determined if employees were using Illegal Tax Protester or any similar designations within the Activity Code field on the Taxpayer Information File by securing a copy of the database and analyzing 127,761 open records with activity between October 2009 and September 2010.

III.             Determined if the IRS is using any Frivolous Return Program[8] codes as replacements for Illegal Tax Protester designations by reviewing guidance provided for the Frivolous Return Program and interviewing its Program Coordinator.

IV.             Determined if there is any relationship between Illegal Tax Protester designations and Potentially Dangerous Taxpayer/Caution Upon Contact indicator use on the Master File by reviewing guidance provided for the Potentially Dangerous Taxpayer/Caution Upon Contact Program[9] and interviewing its Program Coordinator.

V.                Determined if the IRS Nonfiler Program[10] is in compliance with the provisions established by RRA 98 § 3707(b) by reviewing guidance provided for the Nonfiler Program and interviewing its Program Coordinators.

VI.             Determined if the IRM contained Illegal Tax Protester or any similar designations by performing key word searches on electronic versions found on the IRS Electronic Publishing web site, the IRM Online and on CD-ROM, the Servicewide Electronic Research Program, IRS.gov web site, and the IRS Chief Counsel Directives Manual.  We performed our review tests between August and September 2010.

VII.          Determined if employees were using the Illegal Tax Protester or any similar designations within taxpayer case narratives on the Appeals Centralized Database System by securing a copy of the database as of September 2010 and analyzing 3,425,949 open/closed Appeals function narrative comment records with activity between October 2009 and September 2010.

VIII.       Discussed with TIGTA Counsel the potential for agreement with IRS Counsel regarding the use of Illegal Tax Protester or similar designations in electronic case narratives. 

Internal controls methodology

Internal controls relate to management’s plans, methods, and procedures used to meet their mission, goals, and objectives.  Internal controls include the processes and procedures for planning, organizing, directing, and controlling program operations.  They include the systems for measuring, reporting, and monitoring program performance.  We determined the following internal controls were relevant to our audit objective:  controls that ensure the reliability of the data used for our analyses, including input validation.  During our review, we tested the validity of the data used for our analyses against the source, but we did not perform any specific testing of data input controls.  However, it should be noted that data from these same systems were used during prior audits of Illegal Tax Protestor designations and no significant data issues were identified. 

 

Appendix II

 

Major Contributors to This Report

 

Margaret E. Begg, Assistant Inspector General for Audit (Compliance and Enforcement Operations)

Frank Dunleavy, Audit Director

Alan Lund, Audit Manager

David Hartman, Lead Auditor

Craig Pelletier, Senior Auditor

Stanley Pinkston, Senior Auditor

James Allen, Information Technology Specialist

Arlene Feskanich, Information Technology Specialist

 

Appendix III

 

Report Distribution List

 

Commissioner  C

Office of the Commissioner – Attn:  Chief of Staff  C

Commissioner, Small Business/Self-Employed Division  SE:S

Commissioner, Wage and Investment Division  SE:W

Chief, Appeals  AP

National Taxpayer Advocate  TA

Chief Technology Officer  OS:CTO

Director, Office of Research, Analysis, and Statistics  RAS

Director, Communications and Liaison, National Taxpayer Advocate  TA:CL

Director, Office of Servicewide Policy, Directives, and Electronic Research  RAS:SPDER

Director, Communications, Liaison, and Disclosure, Small Business/Self-Employed Division  SE:S:CLD

Director, Strategy and Finance, Wage and Investment Division  SE:W:S

Director, Accounts Management, Wage and Investment Division  SE:W:CAS:AM

Chief, Performance, Evaluation and Improvement, Wage and Investment Division  SE:W:S:PRA:PEI

Chief Counsel  CC

Director, Office of Legislative Affairs  CL:LA

Director, Office of Program Evaluation and Risk Analysis  RAS:O

Office of Internal Control  OS:CFO:CPIC:IC

Audit Liaisons:

GAO/TIGTA Liaison, Deputy Commissioner for Operations Support  OS

GAO/TIGTA Liaison, Deputy Commissioner for Services and Enforcement  SE

GAO/TIGTA Liaison, National Taxpayer Advocate  TA

GAO/TIGTA Liaison, Chief Technology Officer  OS:CTO:SM:PO

Chief, GAO/TIGTA/Implementation Branch  SE:S:CLD:PSP:GTI

Senior Operations Advisor, Wage and Investment Division  SE:W:S

 

Appendix IV

 

Outcome Measure

 

This appendix presents detailed information on the measurable impact that our recommended corrective action will have on tax administration.  While no recommendations were made in this report, the TIGTA has made prior recommendations that continue to provide benefits.  This benefit will be incorporated into our Semiannual Report to Congress.

Type and Value of Outcome Measure:

·         Taxpayer Rights and Entitlements – Actual; 38 taxpayers potentially affected (see page 4).

Methodology Used to Measure the Reported Benefit:

We reviewed:

 

Appendix V

 

Glossary of Terms

 

Appeals Centralized Database System

Appeals function database system used by Appeals Officers, Settlement Officers, managers, and technical analysts to track case receipts, record case time, document case actions, and monitor the progress of the Appeals function workload.

Business Master File

The IRS database that consists of Federal tax-related transactions and accounts for businesses.  These include employment taxes, income taxes on businesses, and excise taxes.

Campus

The data processing arm of the IRS.  The campuses process paper and electronic submissions, correct errors, and forward data to the Computing Centers for analysis and posting to taxpayer accounts. 

Individual Master File

The IRS database that maintains transactions or records of individual tax accounts.

Internal Revenue Manual

A manual containing the IRS’s internal guidelines.

Master File

The IRS database that stores various types of taxpayer account information.  This database includes individual, business, and employee plans and exempt organizations data.

Servicewide Electronic Research Program

An electronic researching tool containing many former paper research applications (e.g., publications, the Internal Revenue Manual, and the Probe and Response Guide).

Taxpayer Delinquent Account

A computer-generated printout indicating that the taxpayer’s account has reached a delinquent status.


Taxpayer Delinquent Investigation

A computer-generated printout indicating that a taxpayer is delinquent filing a return.


Taxpayer Identification Number

A nine-digit number assigned to taxpayers for identification purposes.  Depending upon the nature of the taxpayer, the Taxpayer Identification Number is an Employer Identification Number, a Social Security Number, or an Individual Taxpayer Identification Number.

Taxpayer Information File

A file containing entity and tax data processed at a given campus for all Taxpayer Identification Numbers.

 



[1] Pub. L. No. 105-206, 112 Stat. 685 (codified as amended in scattered sections of 2 U.S.C., 5 U.S.C. app., 16 U.S.C., 19 U.S.C., 22 U.S.C., 23 U.S.C., 26 U.S.C., 31 U.S.C., 38 U.S.C., and 49 U.S.C.).

[2] Pub. L. No. 105-206, 112 Stat. 685 (codified as amended in scattered sections of 2 U.S.C., 5 U.S.C. app., 16 U.S.C., 19 U.S.C., 22 U.S.C., 23 U.S.C., 26 U.S.C., 31 U.S.C., 38 U.S.C., and 49 U.S.C.).

[3] See Appendix V for a glossary of terms.

[4] Fiscal Year 2003 Statutory Audit of Compliance With Legal Guidelines Prohibiting the Use of Illegal Tax Protester and Similar Designations (Reference Number 2003-40-098, dated April 14, 2003).

[5] Pub. L. No. 105-206, 112 Stat. 685 (codified as amended in scattered sections of 2 U.S.C., 5 U.S.C. app., 16 U.S.C., 19 U.S.C., 22 U.S.C., 23 U.S.C., 26 U.S.C., 31 U.S.C., 38 U.S.C., and 49 U.S.C.).

[6] See Appendix V for a glossary of terms.

[7] A Transaction Code 148 causes the accelerated issuance of a Taxpayer Delinquent Investigation or Taxpayer Delinquent Account.

[8] The Frivolous Return Program handles taxpayers who file tax returns based on some type of frivolous argument that justifies payment of little or no income tax.  This would include filing a tax return claiming no income because paying taxes is voluntary or claiming to be a citizen of a State but not a citizen of the United States.

[9] The Potentially Dangerous Taxpayer/Caution Upon Contact Program handles taxpayers who have assaulted and/or threatened IRS employees.

[10] The Nonfiler Program handles taxpayers who fail to file their required returns.

[11] See Appendix V for a glossary of terms.