The Revenue Officer's Conflict of Interest

The Front Line of IRS Collections

First, let’s explain what a Revenuer Officer is and does.

The IRS Revenue Officer is considered the front line of the IRS Collections division. They are charged with collecting larger individual tax liabilities and business tax liabilities. The bulk of their cases focus on payroll tax debts. In general, 941 payroll tax liabilities grow much bigger, much quicker than individual income tax liabilities.

ROs work cases in a specific geographic area from a local office. They communicate with their taxpayers in person, via telephone and fax. And, as part of the IRS collection system, they send notices and letters through the mail.

IRS Revenue Officers are highly trained collection agents. Serve yourself well and don’t forget this fact!

Tax Collector or Taxpayer Advocate?

Consider the following statements.

Collects delinquent tax and secures delinquent returns from taxpayers who have not resolved their obligations in response to prior correspondence or other contact.
Provides customer service by respecting and explaining the taxpayer's rights, IRS policies and procedures. Provides instructions, and analyzes issues presented by taxpayers, practitioners and IRS employees.
Takes appropriate enforced collection action, such as levies, redemptions, seizures, nominee liens, judicial actions, or fraud investigation.

At first glance, you may not see anything wrong with this. But, what if I told you that these statements come from the same IRS job description for Revenue Officers? Now, don’t they seem to contradict each other?

Simplify them a little bit – collect taxes that are delinquent and provide guidance and service on a wide range of financial problems.

WHAT? The IRS expects its Revenue Officers to be both bill collector and financial advisor? Doesn’t that get a little bit messy, or a lot messy? Remember, this job description is taken from the Business and Tax Enforcement section of the IRS job listings, not the Financial Guidance and Service of Taxpayers section (I don't believe this section exists). The guidance that Revenue Officers give on your financial problems typically sounds something like, you can’t pay these other bills until you pay the tax I’m collecting. What else would you expect from a bill collector?

What about the next 2 statements?

Garnish bank accounts and wages as well as seize real and personal property to satisfy delinquent taxes.
Inform taxpayers of their rights under the law and provide them with quality customer service while ensuring their own personal safety and well being.

Yup, you guessed it; taken from the same Revenue Officer job description.

Simplified – Garnish and seize property while informing you of your rights under the law.

And, why is the job title Revenue Officer? Why not Revenue Clerk or Revenue Staffer?

It’s no accident that this sounds like a law enforcement job description. That’s because it is a law enforcement job description. The IRS is a law enforcement agency! Don’t forget this either.

And, do we need to talk about quality customer service? Give me a break!

What I’m trying to point out is that IRS Revenue Officers have a glaring conflict of interest built in to their responsibilities. And, you should retain a professional Power of Attorney Representative (that’s us) when dealing directly with one of them, because a Revenue Officer is a bill collector, not your advocate.

IRS Publication 1, Your Rights as a Taxpayer

IRS Publication 1, Your Rights as a Taxpayer states:

2. The Right to Quality Service

Taxpayers have the right to receive prompt, courteous, and professional assistance in their dealings with the IRS, to be spoken to in a way they can easily understand, to receive clear and easily understandable communications from the IRS, and to speak to a supervisor about inadequate service.

4. The Right to Challenge the IRS’s Position and Be Heard

Taxpayers have the right to raise objections and provide additional documentation in response to formal IRS actions or proposed actions, to expect that the IRS will consider their timely objections and documentation promptly and fairly, and to receive a response if the IRS does not agree with their position.

Hate to go on about it, but does this sound like your Revenue Officer?

Quality Service? The Right to Be Heard?

Didn’t think so.

Professional Collection, Professional Representation

Revenue Officers are eligible to become an Enrolled Agent after 5 years of service as an IRS employee. They get to skip the testing that the rest of us go through to get the EA license. Many Revenue Officers out there are still working toward that 5-year mark. M&M has been licensed since 2005.

Doesn’t it make sense to have an Enrolled Agent on your team to deal directly with your Revenue Officer?

There is a reason that IRS Publication 1, Your Rights as a Taxpayer also states:

Taxpayers have the right to retain an authorized representative of their choice to represent them in their dealings with the IRS.

That’s because it’s unfair to expect taxpayers to compete with the IRS at its own game.

Meet M&M’s Enrolled Agents

At M&M, we’ve been dealing directly with Revenue Officers since 2005. We are your advocate. There is no confusion or conflict of interest.

We help our clients exercise their taxpayer rights under the law every day. You talk to us, we work with the IRS on your behalf.

Contact us to find out how we help people fix tax problems.