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IRS Addresses Systemic Flaws

By Gerard I. Borod

Have you identified any problems that might affect multiple taxpayers and possibly relate to Internal Revenue Service administrative procedures, policies or problems caused by existing tax law? If so, then the Taxpayer Advocate Service wants to make sure you’re aware of the Office of Systemic Advocacy.

Systemic Advocacy operates within the Taxpayer Advocate Service and also is an independent organization that proposes changes to the IRS. Issues this office addresses include the following:

  • Issues that always affect multiple taxpayers.
  • Issues that are not individual taxpayer cases.
  • Issues that affect segments of the taxpayer population, locally, regionally or nationally.
  • Issues that relate to IRS systems, policies and procedures.
  • Issues that require study, analysis, administrative changes or legislative remedies.
  • Issues that involve protecting taxpayer rights, reducing or preventing taxpayer burden, ensuring equitable treatment of taxpayers or providing essential services to taxpayers.

To submit an issue to the Office of Systemic Advocacy, go to www.irs.gov/advocate, click on “What Is Systemic Advocacy?” and complete Form 14411 (Systemic Advocacy Issue Submission Form). A hyperlink is provided. This information can be saved and forwarded to Systemic.Advocacy@irs.gov or fax issues to 202-622-3125. Please do not include a taxpayer’s personal information, such as Social Security numbers or tax data. Updates will be made to the web pages on an ongoing basis to allow ease of use in submitting systemic advocacy issues.


Gerard I. Borod, a partner with Pustorino Puglisi & Company LLP in New York City, is chair of the NYSSCPA’s Relations with the Internal Revenue Service Committee.

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