High-Income Non-Filers Will Be Subject To Increased IRS Visits

On February 19, 2020, the IRS issued a news release announcing that "it will step up efforts to visit high-income taxpayers who in prior years have failed to timely file one or more of their tax returns."1 Specifically, IRS revenue officers (trained civil enforcement officers) across the nation will be increasing their in-person visits with high-income taxpayers who have not filed tax returns in 2018 or earlier years. While the IRS claims that the primary goals of these visits are to inform high-income taxpayers of their reporting and paying obligations and to bring them into compliance, the IRS emphasizes that:

Taxpayers who exercise their best efforts in filing their tax returns and paying or entering into agreements to pay their taxes deserve to know that the IRS is aggressively pursuing others who have failed to satisfy their filing and payment obligations.2

The IRS explained in the news release that high-income non-filers are generally considered to be taxpayers whose income exceeded $100,000 during a tax year and failed to file an IRS tax return. According the IRS, the visiting revenue officers will "share information" with the taxpayer and work with him or her to try to find a tax resolution.

Moreover, in the news release, the IRS reminded taxpayers across all income categories that their 2019 tax returns are due April 15, regardless of whether they can pay in full. While six-month filing extensions are available, the IRS clarified that an extension for filing does not extend the April 15 deadline for paying any amount of taxes owed.

Significantly, the IRS notes that the increase in revenue officer visits highlights how important it is for taxpayers to file on time, even if they can pay along with their return. The news release cites Hank Kea, Director of Field Collection Operations, Small Business/Self Employed Division, stating that:

Not filing because you don't believe you can pay at the time of filing makes the problem worse, as interest and penalties mount over time. We have many payment options available on IRS.gov to help taxpayers. It's better to work on these issues up front rather than ignoring it and ultimately getting to the point of the IRS taking more serious action. Our continued use of ever-changing technologies, coupled with additional enforcement personnel, would suggest that waiting is not a viable option for delinquent taxpayers.3

The IRS was careful to point out that the visits are not scams and provided the following information for taxpayers to use in distinguishing a legitimate visit from a scam:

  • IRS revenue officers usually do not announce their visits, but they will provide two forms of official credentials, each displaying a photo of the officer and the officer's serial number.
  • Authentic revenue officers help taxpayers understand and fulfill their tax obligations; revenue officers explain liabilities and consequences, but they do not make threats or demand an "unusual" form of payment for a liability that doesn't exist.
  • Usually taxpayers have received multiple IRS notices via mail before a revenue officer makes a visit.
  • Revenue officers will provide various options for payment, including payment by check to the U.S. Treasury.
  • Taxpayers can find more information regarding distinguishing legitimate IRS personnel at IRS.gov.

Finally, taxpayers are well-advised to heed the following quote from Paul Mamo, Director of Collection Operations, Small Business/Self Employed Division, "[t]axpayers having delinquent filing or payment obligations should consult a competent tax advisor before waiting to be contacted by an IRS revenue officer."4

*Editor's Note: Also, in February of 2020, the IRS issued FS-2020-02, reflecting on this announcement. Therein, the IRS stated that to further promote voluntary compliance, it will employ new ways to improve existing systems in place. Per FS-2020-02, the processes, or systems, effected will include:

  • Increase the identification and case creation for individual and business non-filers. New cases will be assigned to IRS employees for appropriate resolution.
  • Automated Substitute for Return program (ASFR). This affects individual taxpayers who have not filed tax returns, but whose available income information shared with the IRS indicates a significant income tax liability. As part of the ASFR program, the IRS sends notices to these taxpayers alerting them to the potential liability.
  • Automated 6020(b) process. Promotes employment tax filing compliance by identifying business taxpayerswith employment tax requirements who have not filed for a specific period. Ensuring businesses comply withtheir employment tax filing and payment requirements is another priority for the IRS.
  • Delinquent Return Refund Hold program (DRRH). Systemically holds an individual taxpayer's income taxrefund when their account has at least one unfiled tax return within the five years surrounding that return.5

If you have delinquent tax filing or payment obligations, contact Frost & Associates, LLC today at 410-497-5947.

1 IR-2020-34 (Feb. 19, 2020). You can read the News Release in full at: https://www.irs.gov/newsroom/irs-increases-visits-to-high-income-taxpayers-who-havent-filed-tax-returns.

2 Id.

3 Id.

4 Id.

5 FS-2020-02 (Feb. 2020). You can read the entire fact sheet at: https://www.irs.gov/newsroom/irs-increasing-focus-on-taxpayers-who-have-not-filed-tax-return.

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