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.