Fiscal Year 2004 Statutory Audit of Compliance With Legal Guidelines Prohibiting the Use of Illegal Tax Protester and Similar Designations

 

June 2004

 

Reference Number:  2004-40-109

 

 

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

 

June 7, 2004

 

 

MEMORANDUM FOR DEPUTY COMMISSIONER FOR SERVICES AND ENFORCEMENT

                                         DEPUTY COMMISSIONER FOR OPERATIONS SUPPORT

 

FROM:     Gordon C. Milbourn III /s/ Gordon C. Milbourn III

                 Acting Deputy Inspector General for Audit

 

SUBJECT:     Final Audit Report - Fiscal Year 2004 Statutory Audit of Compliance With Legal Guidelines Prohibiting the Use of Illegal Tax Protester and Similar Designations  (Audit # 200340053)

 

This report presents the results of our review to determine if the Internal Revenue Service (IRS) complied with the IRS Restructuring and Reform Act of 1998 (RRA 98) Section (§) 3707 and internal IRS guidelines that prohibit IRS officers and employees from referring to taxpayers as Illegal Tax Protesters (ITP) or any similar designations.

Prior to enactment of the RRA 98, taxpayers were referred to the ITP 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.  Once a taxpayer’s account was coded as an ITP, certain tax enforcement actions were accelerated.  The designation was also intended to alert IRS employees to be cautious so they would not be drawn into confrontations.

RRA 98 § 3707 prohibits the IRS from referring to taxpayers as ITPs or any similar designations.  The Treasury Inspector General for Tax Administration is required to annually evaluate the IRS’ compliance with the prohibition on the use of ITP or any similar designations.

The IRS has not reintroduced past ITP codes on the Master File, and formerly coded ITP taxpayer accounts have not been assigned similar ITP designations.  However, a few taxpayers’ records were coded as tax protesters on the Taxpayer Information File (TIF) and the Integrated Collection System (ICS) computer systems.  In addition, the IRS does not have any current publications with ITP references.  While the IRS has made some effort to remove ITP references from the various forms of the Internal Revenue Manual (IRM), it did not ensure that all corrections were completed.  As a result, 103 ITP references still existed as of January 2004.  In addition, three ITP references were identified in the Job Aids.

In addition, in isolated instances IRS employees continued to make references to taxpayers as ITPs and other similar designations in case narratives.  The IRS has taken steps in directing its employees to prevent ITP and similar designations from appearing in case narratives.  However, in its response to our Fiscal Year 2003 report, the IRS disagreed with our determination that to comply with this provision, IRS employees should not designate taxpayers as ITPs 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 Treasury, but have not yet received a response.

We recommended that the Chief Information Officer take the appropriate steps to remove the tax protester coding from the TIF and the ICS and strengthen controls to prevent these computer systems from accepting such coding.  We also recommended that the Commissioners, Small Business/Self-Employed (SB/SE) Division and Tax Exempt and Government Entities (TE/GE) Division; the Chief, Agency-Wide Shared Services; and the Chief Counsel take the necessary actions to ensure that the remaining ITP references are promptly removed from all versions of the IRM and the Job Aids.  Since the IRS has taken interim action to deter employees from using ITP or similar designations in case narratives and there is an outstanding question concerning the legal interpretation of the RRA 98 § 3707, we believe that no further recommendations are needed at this time.

Management’s Response:  IRS management agreed with our recommendations.  The IRS will remove the instances of tax protester coding that currently reside on the TIF and the ICS, and add new validation to prevent any additional entries.  In addition, both the SB/SE and TE/GE Divisions and the Chief, Agency‑Wide Shared Services, have taken actions to remove ITP references from all versions of the IRM and IRS Job Aids.  Chief Counsel has revised their Chief Counsel Directives Manual to remove all ITP references; however, revisions are in the clearance process.  Management’s complete response to the draft report is included as Appendix VII.

Copies of this report are also being sent to the IRS managers affected by the report recommendations.  Please contact me at (202) 622-6510 if you have questions or Michael R. Phillips, Assistant Inspector General for Audit (Wage and Investment Income Programs), at (202) 927-0597.

 

Table of Contents

Background

Illegal Tax Protester Codes Were Not Used on the Master File but Were Identified on Other Computer Systems

Recommendation 1:

Internal Revenue Service Publications Do Not Contain Illegal Tax Protester References

The Internal Revenue Manual and Job Aids Contained Illegal Tax Protester References

Recommendation 2:

Employees Used Illegal Tax Protester or Similar Designations in Isolated Instances in Case Narratives

Appendix I – Detailed Objective, Scope, and Methodology

Appendix II – Major Contributors to This Report

Appendix III – Report Distribution List

Appendix IV – Outcome Measures

Appendix V – Use of Illegal Tax Protester and Similar Designations in Case Narratives by Internal Revenue Service Employees During Fiscal Years 2002, 2003, and 2004

Appendix VI – Examples of Illegal Tax Protester and Similar Designations Found in Case Narratives

Appendix VII – Management’s Response to the Draft Report

 

Background

The Internal Revenue Service (IRS) Restructuring and Reform Act of 1998 (RRA 98) Section (§) 3707 prohibits the IRS from referring to taxpayers as Illegal Tax Protesters (ITP) or any similar designations.  In addition, the RRA 98 requires the removal of all existing ITP codes from the IRS’ Master File and instructs IRS employees to disregard any such designation not located on the Individual Master File (IMF).

Prior to enactment of the RRA 98, taxpayers were referred to the ITP 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.  Once a taxpayer’s account was coded as an ITP, certain tax enforcement actions were accelerated.  The designation was also intended to alert IRS employees to be cautious so they would not be drawn into confrontations.

The Congress had concerns that some taxpayers were being permanently labeled and stigmatized by the ITP designation.  Taxpayers who subsequently complied with the tax laws could continue to be labeled as ITPs, which could bias IRS employees and result in unfair treatment.

Internal Revenue Code § 7803(d)(1)(A)(v)(2000) requires the Treasury Inspector General for Tax Administration to annually evaluate the IRS’ compliance with the prohibition against using ITP or any similar designations.  This is our sixth review since Fiscal Year (FY) 1999.  These reviews have identified areas for improvement to help the IRS comply with the ITP designation prohibition.

This review was performed in the IRS National Headquarters in Washington, D.C., during the period August 2003 through March 2004.  The audit was conducted in accordance with Government Auditing Standards.  Detailed information on our audit objective, scope, and methodology is presented in Appendix I.  Major contributors to the report are listed in Appendix II.

Illegal Tax Protester Codes Were Not Used on the Master File but Were Identified on Other Computer Systems

In prior reviews, we reported that the IRS had removed the ITP codes from the Master File as required by the RRA 98 § 3707.  The ITP designation has not been reintroduced on the Master File. 

The RRA 98 § 3707 also prohibits using any designation similar to the ITP.  A review of the approximately 57,000 taxpayer accounts formerly coded as ITPs on the Master File identified no reassignments of these taxpayer accounts to any other Master File designations.

In addition to the Master File, the IRS uses other computer inventory systems to manage taxpayer cases.  This year we reviewed approximately 24.7 million taxpayer accounts on the Taxpayer Information File (TIF), identifying 47 taxpayer records that contained codes designating them as tax protesters.  Additionally, a review of approximately 1.5 million Integrated Collection System (ICS) taxpayer accounts disclosed another 26 taxpayers accounts that were coded as tax protesters.

IRS officials informed us that these tax protester codes had been input during the last 18 months but could not determine why the codes had been input.  In addition, these codes were not visible to employees researching ICS.  Although the RRA 98 did not specifically require the removal of tax protester codes on these computer systems, the use of such coding, based on the language of the statute, would appear to be contrary to the intent of the Congress.

Recommendation

1.      The Chief Information Officer should take the appropriate steps to remove the tax protester coding from the TIF and the ICS, and strengthen controls to prevent these computer systems from accepting such coding.

Management’s Response:  IRS management will remove the instances of tax protester coding that currently reside on the TIF and the ICS and add new validation to prevent any additional entries.

Internal Revenue Service Publications Do Not Contain Illegal Tax Protester References

To help promote compliance with the RRA 98 § 3707, IRS management issued directives for employees to update various publications to eliminate references to ITP terminology and programs.  A review of IRS publications identified no ITP references.  The IRS has labeled those publications with ITP references identified in our previous reviews as obsolete.

The Internal Revenue Manual and Job Aids Contained Illegal Tax Protester References

During each of the five prior reviews, we identified multiple subsections throughout the various forms of the Internal Revenue Manual (IRM) that contained ITP references.  In August 2002, the IRS responded to our FY 2002 report stating that each IRS function responsible for manual updates would delete these references from the IRM.  There were a total of 144 of these references throughout the various forms of the IRM as of March 2002.  Although according to the IRS, this corrective action was completed in April 2003, many of these references still exist.

While the IRS has made some effort to remove ITP references from the various forms of the IRM, it did not ensure that all corrections were completed.  As a result, 103 ITP references still existed as of January 2004, with the majority of them found in the Chief Counsel’s portions of the IRM.  In addition, we identified 3 ITP references in the IRS Job Aids.  The existence of ITP references in the IRM and the Job Aids may encourage IRS employees to improperly label taxpayers.

The following chart compares the number of unique ITP references in the IRM and the Job Aids identified during our FY 2004 review.

Comparison of Unique Illegal Tax Protester References in the IRM and Job Aids by IRS Function

Source:  Current versions of the IRM and Job Aids.

In responding to our FY 2002 report, the IRS stated that the IRS functions were to delete these references from their portions of the IRM.  In addition, the Office of Servicewide Policy, Directives, and Electronic Research was to continue to manage the Internal Management Documents process by coordinating requests from the Multimedia Publishing Division to search the various IRM files for ITP references.  We did not find any evidence that these searches were conducted.

Recommendation

2.      The Commissioners, Small Business/Self-Employed (SB/SE) Division and Tax Exempt and Government Entities (TE/GE) Division; the Chief, Agency-Wide Shared Services; and the Chief Counsel should take the necessary actions to ensure that the remaining ITP references are promptly removed from all versions of the IRM and IRS Job Aids.

Management’s Response:  The SB/SE and TE/GE Divisions and the Chief, Agency-Wide Shared Services, have taken actions to remove ITP references from all versions of the IRM and IRS Job Aids.  Chief Counsel has revised their Chief Counsel Directives Manual to remove all ITP references; however, revisions are in the clearance process.

Employees Used Illegal Tax Protester or Similar Designations in Isolated Instances in Case Narratives

Our FY 2004 review of a sample of computer systems and paper files used by IRS employees to document case activity identified 233 isolated instances where 206 employees designated taxpayers as “tax protesters,” “ITPs,” “constitutionally challenged,” or other similar designations.  These actions are prohibited by the RRA 98 § 3707.

Employees are allowed to document any statements made by a taxpayer or their representatives.  Quoting a taxpayer’s self-designation as an ITP is not prohibited by the RRA 98 § 3707.  However, examples of inappropriate IRS employee comments can be found in Appendix VI, and a breakdown of where comments were made can be found in Appendix V.

The IRS has taken steps in directing its employees to prevent ITP and similar designations from appearing in case narratives.  On October 11, 2002, the IRS issued a Servicewide Electronic Research Program (SERP) alert reminding employees of the prohibition regarding the use of ITP or any similar designations.  Business and functional units independently continue to take additional steps to address this issue.  These included sending out additional guidance in the form of SERP alerts, e-mail alerts and memorandums, updating training, conducting quality reviews for ITP usage, and counseling employees that continued to designate taxpayers as ITPs or other similar designations.

However, in its response to our FY 2003 report, the IRS disagreed with our determination that in order to comply with this provision, IRS employees should not designate taxpayers as ITPs or similar designations in case narratives.  As a result, we elevated this disagreement to the Assistant Secretary for Management and Chief Financial Officer of the Treasury, but have not yet received a response.

We believe that it is reasonable to conclude, based upon the language of the statute, that IRS officers and employees should not label taxpayers as ITPs or similar designations in any IRS records, which includes paper and electronic case files.  We agree with the IRS that merely making references to taxpayers’ actions (e.g., indicating the type of document the taxpayer files or that the taxpayer files letters containing typical protester language) does not constitute a designation prohibited by this statutory provision.  IRS officers and employees should not, however, designate taxpayers as ITPs or similar designations because such a designation alone contains a negative connotation and appears to label the taxpayer.

In isolated instances, employees referred to taxpayers using ITP designations in case narratives on the following IRS computer inventory management systems and paper case files:

·         Automated Collection System (ACS):  A review of approximately 2.5 million open ACS records identified 44 cases in which 41 employees used ITP or similar designations when referring to specific taxpayers in their case narratives.

·         Criminal Investigation Management Information System (CIMIS):  A review of 9,353 open cases identified 5 cases in which 5 employees used ITP or similar designations when referring to specific taxpayers in their case narratives.

·         Examination Function Paper Case Files:  A review of a judgmental sample of 557 taxpayers identified 3 cases in which 3 employees used ITP or similar designations when referring to specific taxpayers in their paper case files.

·         Integrated Collection System:  A review of approximately 1 million open ICS records identified 177 cases in which 153 employees used ITP or similar designations when referring to specific taxpayers in their case narratives.

·         Taxpayer Advocate Management Information System (TAMIS):  A review of 33,718 open TAMIS records identified 4 cases in which 4 employees used ITP or similar designations when referring to specific taxpayers in their case narratives.

We identified 90 additional instances in various case narratives where employees had used the term tax protester or similar references.  In general, employees had used these terms to describe the type of action taken by the taxpayer and had not specifically designated taxpayers as “protesters.”  While these actions are not prohibited by the RRA 98 § 3707, we are concerned that these references could become, or be considered, permanent labels that could subsequently stigmatize taxpayers in future contacts with the IRS.

Since the IRS has taken interim action to address these issues and there is an outstanding question concerning the legal interpretation of the RRA 98 § 3707, we believe that no further recommendations are needed at this time.

 

Appendix I

 

Detailed Objective, Scope, and Methodology

 

The objective of this review was to determine if the Internal Revenue Service (IRS) complied

with the IRS Restructuring and Reform Act of 1998 (RRA 98) Section (§) 3707 and internal IRS guidelines that prohibit referring to taxpayers as Illegal Tax Protesters (ITP) or any similar designations.  The Treasury Inspector General for Tax Administration (TIGTA) is required to annually evaluate the IRS’ compliance with the prohibition against using ITP or any similar designation.  To complete this objective, we:

 

I.                    Determined if the ITP coding on the IRS’ Master File was removed by reviewing all Accelerated Issuance Codes (Transaction Code 148) as of November 2003 for Business Master File (BMF) records and Individual Master File (IMF) records.  We reviewed 160,114 BMF records and 570,876 IMF records.  We generally relied on the TIGTA’s Office of Information Technology for validation of the data provided to us.  However, we did a limited validation of the data by researching a judgmental sample of 25 Taxpayer Identification Numbers (TIN) and 25 Employer Identification Numbers (EIN) on the Integrated Data Retrieval System (IDRS).

We also compared our historic computer extract of approximately 57,000 taxpayers designated as ITPs before the RRA 98 was enacted to our BMF and IMF records with an Accelerated Issuance Code (Transaction Code 148) to determine if any new common codes were being used to classify them as ITPs.

II.                 Determined if the IRS’ Internal Revenue Manual (IRM) and Job Aids contained ITP or any similar designations by performing key word searches in January 2004 of the Servicewide Policy, Directive, and Electronic Research system; the Servicewide Electronic Research Program (SERP); the IRS’ electronic publishing Intranet web site; the IRS’ public Internet web site; the CD-ROM; and paper IRMs.  We specifically searched for corrections to the exceptions identified in our Fiscal Year 2003 report and determined if there were any new references.

III.               Determined if IRS publications still contained ITP or any similar designations by performing key word searches of the SERP, the IRS’ public Internet web site, and the IRS’ electronic publishing Intranet web site in October 2003.

IV.              Determined if employees were using ITP or any similar designations within taxpayer case narratives on the IRS’ Integrated Collection System (ICS) by securing and analyzing 1,046,459 open ICS records as of September 2003 from a database with history action dates between October 2002 and September 2003.  We did not perform a detailed validation of the ICS data because this information was provided directly from the IRS through the TIGTA Data Center Warehouse (DCW).  However, we did a limited validation of the data accuracy by matching a judgmental sample of 25 TINs to the IDRS to determine if the accounts were in current collection status.

V.                 Determined if employees were using ITP or any similar designations within taxpayer case narratives on the IRS’ Automated Collection System (ACS) by securing and analyzing all 2,537,738 records from the current open database as of the end of September 2003.  We did not perform a detailed validation of the ACS data because this information was provided directly from the IRS through the TIGTA DCW.  However, we did a limited validation of the data accuracy by matching a judgmental sample of 25 TINs to the IDRS to ensure the accounts were in current collection status.

VI.              Determined if employees were using ITP or any similar designations within taxpayer case narratives on the IRS’ Taxpayer Advocate Management Information System (TAMIS) by analyzing the key word query results of 33,718 open TAMIS cases with activity between October 2002 and September 2003.  The Taxpayer Advocate Service provided the data and validation information to us.  The TIGTA DCW staff validated the TAMIS data received.  In addition, we did a limited validation of data accuracy and completeness by looking up a judgmental sample of 25 cases by accessing TAMIS on-line.

VII.            Determined if employees were using ITP or any similar designations within taxpayer case narratives on the IRS’ Appeals Centralized Database System (ACDS) by analyzing 105,615 case records identified as received in the Appeals function between October 2002 and September 2003.  The data were provided directly from the IRS through the TIGTA DCW.  However, we did a limited validation of data accuracy and completeness by looking up a judgmental sample of 36 case records by accessing ACDS on-line.

VIII.         Determined if Examination function employees were using ITP or any similar designations within paper case files by reviewing a judgmental sample of 557 taxpayers previously identified as ITPs.  The sample was selected from 3,666 closed tax return examinations that were closed between October 2002 and June 2003.  We validated record counts for this time period against Examination reports provided by the IRS.

IX.              Determined if Criminal Investigation (CI) function employees were using ITP or any similar designations within taxpayer allegation text by analyzing 9,353 cases opened on the Criminal Investigation Management Information System (CIMIS) between October 2002 and August 2003.  The data were provided directly from the IRS and validated by the TIGTA.  Additionally, we did a limited validation of the data accuracy by matching a judgmental sample of 25 TINs to the IDRS to ensure the existence of criminal investigation activity.

We also compared the historic computer extract of approximately 57,000 taxpayers designated as ITP before the RRA 98 was enacted to the 5,152 cases that the CI function closed between October 2002 and August 2003.  We determined that none of the previously designated ITP taxpayers are in the CI function’s closed case files.

X.                 Determined if the IMF and BMF taxpayers on the Taxpayer Information File (TIF) are coded as ITP by querying the Taxpayer Delinquency Investigation (TDI) Case Code field for the tax protester code “TXPR.”  We reviewed 14,539,900 IMF and 10,123,467 BMF taxpayer accounts on the IDRS during the week of March 1, 2004.  We generally relied on the TIGTA’s Office of Information Technology for validation of the data provided to us.  However, we did a limited validation of the data by researching a judgmental sample of 15 EINs and 10 TINs on the IDRS.

Determined if taxpayers on the ICS are coded as ITP by querying the TDI Case Code field for “TXPR.”  We reviewed 1,507,175 ICS taxpayer records as of February 2004.  We did not perform a detailed validation of the ICS data because this information was provided directly from the IRS through the TIGTA DCW.

We also compared our historic computer extract of approximately 57,000 taxpayers designated as ITPs before the RRA 98 was enacted to our records with a “TXPR” code to determine if any new common codes were being used to classify them as ITPs.

XI.              Consulted with the TIGTA’s Office of Chief Counsel on the correct application of the law.

 

Appendix II

 

Major Contributors to This Report

 

Michael R. Phillips, Assistant Inspector General for Audit (Wage and Investment Income Programs)

Mary V. Baker, Director

Bryce Kisler, Audit Manager

Julia Tai, Senior Auditor

Tracy Harper, Auditor

Jean Kao, Auditor

Craig Pelletier, Auditor

 

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, Tax Exempt and Government Entities Division  SE:T

Commissioner, Wage and Investment Division  SE:W

Director, Communications & Liaison, Small Business/Self-Employed Division  SE:S:MS:CL

Director, Compliance, Small Business/Self-Employed Division  SE:S:C

Director, Compliance, Wage and Investment Division  SE:W:CP

Director, Office of Research, Analysis, and Statistics  RAS

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

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

Chief, Agency-Wide Shared Services  OS:A

Chief, Appeals  AP

Chief Counsel  CC

Chief, Criminal Investigation  SE:CI

Chief Information Officer  OS:CIO

National Taxpayer Advocate  TA

Director, Office of Legislative Affairs  CL:LA

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

Office of Management Controls  OS:CFO:AR:M

Audit Liaisons:

Chief, Customer Liaison, Small Business/Self-Employed Division  SE:S:COM

Commissioner, Tax Exempt and Government Entities Division  SE:T

GAO/TIGTA Liaison, Wage and Investment Division  SE:W:S:PA

GAO/TIGTA Liaison, Modernization & Information Technology Services  OS:CIO:R:PM:PO

 

Appendix IV

 

Outcome Measures

 

This appendix presents detailed information on the measurable impact that our recommended corrective actions in this report and the recommended corrective actions from our Fiscal Year 2002 audit report will continue to have on tax administration.  These benefits will be incorporated into our Semiannual Report to the Congress.

Type and Value of Outcome Measure:

·        Taxpayer Rights and Entitlements – Potential; 306 taxpayers affected (see pages 2 and 5).

Methodology Used to Measure the Reported Benefit:

We reviewed the following:

·        From the Taxpayer Information File (TIF) - approximately 24.7 million taxpayer accounts as of the week of March 1, 2004, and identified 47 taxpayer accounts coded as tax protesters.

·        From the Automated Collection System (ACS) - approximately 2.5 million records from the current open database as of the end of September 2003, and identified 44 taxpayer case narratives that contained Illegal Tax Protester (ITP) or a similar designation.

·        From the Criminal Investigation Management Information System (CIMIS) - a total of 9,353 cases opened between October 2002 and August 2003, and identified 5 taxpayer case narratives that contained ITP or a similar designation.

·        From Examination function paper case files - a total of 557 judgmentally selected taxpayers with tax return examinations closed between October 2002 and June 2003, and identified 3 taxpayer case files that contained ITP or a similar designation. 

·        From the Integrated Collection System (ICS) - approximately 1 million open records with history action dates between October 2002 and September 2003, and identified 177 taxpayer case narratives that contained ITP or a similar designation.  Additionally, from approximately 1.5 million open and archive taxpayer accounts on the ICS at month end February 2004, we identified 26 taxpayer accounts coded as tax protesters.

·        From the Taxpayer Advocate Management Information System (TAMIS) - a total of 33,718 open cases with activity between October 2002 and September 2003, and identified 4 taxpayer case narratives that contained ITP or a similar designation.

Type and Value of Outcome Measure:

·        Reliability of Information – Actual; 103 Internal Revenue Manual (IRM) subsections from various sources affected and 3 Job Aids (see page 3).

Methodology Used to Measure the Reported Benefit:

In January 2004, we searched various versions of the IRM and the Job Aids available to Internal Revenue Service (IRS) employees for ITP references.  These were found on the Servicewide Electronic Research Program (SERP); the IRS’ publishing web site; the IRS’ public Internet web site; the CD-ROM; and on paper.

 

Appendix V

 

Use of Illegal Tax Protester and Similar Designations in Case Narratives by Internal Revenue Service Employees During Fiscal Years 2002, 2003, and 2004

 

Source:  Treasury Inspector General for Tax Administration reports entitled “Efforts Are Still Needed to Discourage the Use of Illegal Tax Protester and Similar Designations” (Reference Number 2002-40-162, dated September 2002), and 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 2003), and various IRS case narratives.

 

Appendix VI

 

Examples of Illegal Tax Protester and Similar Designations Found in Case Narratives

 

During our Fiscal Year 2004 review, we searched for the following words and abbreviations to identify Illegal Tax Protester (ITP) and other similar designations being used by Internal Revenue Service (IRS) employees in their case narratives.  We did not take exception to employee comments quoting a taxpayer’s self-designation as an ITP.

 

 

The following comments made by employees are some examples of ITP and similar designations found in IRS employees’ case narratives.

·        ****1****

 

·        ****1****

 

·        ****1****

 

·        ****1****

 

·        ****1****

 

·        ****1****

 

·        ****1****

 

·        ****1****

 

·        ****1****

 

·        ****1****

 

·        ****1****

 

·        ****1****

 

·        ****1****

 

·        ****1****

 

·       ****1****.

 

·        ****1****

 

Appendix VII

 

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.