Revenue Officer Enforcement

IRS collections cases can be assigned to the Automated Collections Service or to local Revenue Officers for enforced collections.  Generally speaking, larger cases with greater noncompliance or higher complexity warrant Revenue Officer assignment.  However, across the board, the IRS lacks sufficient resources to do its job, and this is very true in the field where Revenue Officers continue to retire or leave the Service without being replaced.

This means that the Revenue Officers who are assigned files for enforcement already have plenty of work to do and insufficient help, or even printer toner, to do it efficiently.  This can manifest itself in the responsiveness, tactics and mood of your Revenue Officer, despite their best efforts to handle every case with respect and professionalism.

Revenue Officers have a great deal more discretion and authority to run their files as they wish, as compared to an Automated Collections Service representative, who may only touch a file a single time.  Revenue Officers also have a few more powerful enforcement tools at their disposal, including retirement/investment fund levies, property seizure, summons, third-party subpoenas, and suits to reduce debts to judgment.  They can also simply come out to a taxpayer’s home or job or place of business to visit with the taxpayer in person.  And, on the way back to their office, stop off at the taxpayer’s bank for a records subpoena and the taxpayer’s biggest client to deliver a levy.

Revenue Officers also handle a great many cases involving payroll tax problems and are responsible for assessing Trust Fund Recovery Penalties against business owners who are behind on payroll taxes.  The Trust Fund Recovery Penalty assessment converts the liabilities of the business into an assessment against the owners (or anyone with responsibility for payroll tax compliance)

These powers and dynamics can make Revenue Officer cases more difficult to manage for the practitioner or more unsettling for the taxpayer.  They also can present opportunities: the Revenue Officer needs to resolve the file and also will generally provide a more consistent negotiation experience than five telephone calls with five different Automated Collections Service reps.

So, the benefits of a Revenue Officer assignment are consistency and flexibility of handling of the file, while the drawbacks are a more heightened urgency and more potent collections techniques and approach.