In April 2020, IRS Revenue Officers were instructed to stay at home and not go into the field –
unless it was absolutely necessary. New guidance extends that direction until January 31st, 2020. This causes some delay for taxpayers because important case files may be at an actual IRS office. The new guidance tells us that face-to-face public contact and field activities shall only occur in “exceptional” cases. That is, face-to-face contact will not be routine or regular. The IRS guidance tells us that face-to-face contact will occur when there are no alternatives to it, when there is a risk of permanent loss to the government, the expiration of a statute, pyramiding of employment taxes or a transfer of assets outside the reach of the government. Face-to-face contact may also occur if a taxpayer’s representative requests a meeting and an IRS Manager approves it.
Of course, all Revenue Officers are expected to wear masks, practice social distancing, and adhere to CDC guidelines – going as far as conducting face-to-face meetings at IRS facilities equipped with plexiglass barriers. This instruction also applies to Offer in Compromise cases, where sometimes Revenue Officer assess property in the field. There was also chatter that COVID-19 delays may pose a threat to the 24-month timeline for Offers to be accepted or rejected. Offers in Compromise that are not actioned by the IRS within a 24-month time frame are deemed accepted. While this may be a minor disruption for the IRS, it is not expected to be a major problem.
Finally, and importantly, the most recent IRS guidance, October 1, 2020, tells us that Revenue Officers should resume normal procedures for filing federal tax liens. As of late, taxpayers have enjoyed a break from the filing of federal tax liens, but no longer. Delayed collection actions are also expected to resume shortly. Pretty soon, it will be business as usual.