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Issue 41405

Tax ID Pin number request process

Issue Statement: The suggestion is for the IRS to review other ways to verify identity from low-income taxpayers. The current process discriminates against them. Low-income people move from place to place for various reasons. In order to get a 6-digit number via text to complete the process, the taxpayer must have a mortgage loan number (they may not own a home), a credit card number (they do not always have credit cards and debit cards are not permissible), auto loans (they may not have a car and therefore use public transportation), a cell phone with major carriers (many have prepaid cell phones). Low income people need their refund and many can’t verify their identity by using the on-line option because they cannot provide the required information to obtain a 6-digit pin number.

Also taxpayers who have been the victim of identity theft are now receiving CP 5747C letters, requiring them to physically appear in person at an IRS office to prove their identity. Not only does this apparently cause a lot of concern to those who receive this letter, it also requires them to make an appointment. A couple of matters were raised: first, taxpayers who are not proficient in English may just go directly to an IRS office without understanding they need to make an appointment, or what specific documents to bring with them; and second, this requirement to physically present oneself can be a terrible inconvenience to some taxpayers given the hours when IRS offices are open (surgeons and medical professionals were one example) or the distance required to get to one.

The question from the group was whether there was one or more options for people to be “validated” without personally appearing. There was push-back from the IRS to the suggestion that tax practitioners should be allowed to use a POA or something similar to validate a client. (While most practitioners are honest, there have apparently been over 3,000 practitioners sanctioned over the years and we’re all familiar with the “refund mills” run by some.) In any case, there was a suggestion that a “certified acceptance agent” could be used to perform this validation. While I’ll admit I have no idea what a certified acceptance agent is (or how you become one), the IRS seemed to think there might be some merit in this idea.

Goal Statement: To determine if the current IRS requirements for verifying identity have a disproportionate effect on taxpayers or might be impossible for low-income taxpayers to achieve. If true then making changes to any guidance that would ensure taxpayers the ability to acquire an Identity Protection Personal Identification Number (IP PIN) needs to be implemented in all applicable instructions, forms, and guides. Also to determine if the IRS requirements for taxpayers who are victims of identity theft to appear in person at an IRS office may be overly burdensome.

TAP RECOMMENDATION

Issue 41405 Should it be approved that additional options are needed to ensure taxpayers have the ability to acquire an IP PIN and/or the IRS wants to relax the appear-in-person requirements for Victims of ID Theft Issued Letter CP 5747C, then one suggestion would be to utilize a system already in place as an acceptance agent, such as existing Low Income Taxpayer Clinic (LITC) sites. Then make the following changes.

IRS Action:Not adopted

Issue 41405

Currently, eligible taxpayers may opt-in to receive an IP PIN that will proactively protect their tax account from a fraudulent filing. The opt-in process uses the Get an IPPIN web tool and requires identity verification through the secure access application. We are currently exploring alternative methods for obtaining an IP PIN that would be tailored to low income taxpayers and provide options for verification other than through secure access. Once the alternative methods for taxpayers to obtain an IP PIN are available, we will update the information on IRS.gov. We will also advise our customer service representatives (CSRs) of all the options available to taxpayers to obtain an IP PIN.

We are currently exploring alternative methods for obtaining an IP PIN that would be tailored to low income taxpayers and provide options for verification other than through secure access. Once the alternative methods for taxpayers to obtain an IP PIN are available, we will update the information on IRS.gov. We will also advise our customer service representatives (CSRs) of all the options available to taxpayers to obtain an IP PIN.

We feel making updates to the Form 1040 instructions, page 25, would not be appropriate at this time. The information on page 25, Form 1040 instructions, is not meant to provide guidance on how to apply for an IP PIN. The information explains how to input an IP PIN that has already been assigned to the taxpayer. Annually, taxpayers with an existing IP PIN requirement, receive a notice (CP01A) with a new IP PIN to use on filings for that year. The telephone number (800) 908-4490, and the IRS.gov/CP01A website are references to assist taxpayers who lost their IP PIN or did not receive a notice CP 01A as expected.

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