Overview
Title
Proposed Extension of Information Collection Request Submitted for Public Comment; Comment Request for Form 14411
Agencies
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The IRS wants people to say if filling out a form about IRS problems is too confusing or takes too much time, and they want kids, parents, or anyone else to suggest ideas to make it better before May 13, 2025.
Summary AI
The Internal Revenue Service (IRS) is seeking public and federal agency comments on the information collection related to Form 14411, which focuses on Systemic Advocacy Issue Submission. This form allows taxpayers, businesses, and other organizations to report systemic issues encountered with IRS processes or suggest legislative changes. The IRS is interested in comments that could help assess the necessity, utility, and clarity of the information collected and ways to minimize the burden on respondents. Comments are due by May 13, 2025.
Abstract
The Internal Revenue Service, as part of its continuing effort to reduce paperwork and respondent burden, invites the public and other Federal agencies to take this opportunity to comment on proposed and/or continuing information collections, as required by the Paperwork Reduction Act of 1995. Currently, the IRS is soliciting comments concerning the burden related to Form 14411, Systemic Advocacy Issue Submission.
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Sources
AnalysisAI
The document from the Federal Register announces a request for comments from the Internal Revenue Service (IRS) regarding Form 14411, involved in Systemic Advocacy Issue Submission. The IRS invites feedback from the public and federal agencies as part of an effort to streamline the process and ease the burden on those who must submit this form. Feedback is requested on various aspects of the form’s purpose, effectiveness, and user-friendliness. Interested parties are encouraged to submit their comments by May 13, 2025, and include specific instructions for email submissions. This document highlights the method and rationale behind collecting responses to improve the form, aligning with the Paperwork Reduction Act of 1995.
Significant Issues and Concerns
One notable issue with the document is that although it provides an email for comments, it lacks detailed guidance on the required format for submissions. Such ambiguity could potentially lead to confusion among respondents who might worry about their feedback being disregarded due to formatting errors.
Additionally, while the IRS is seeking feedback on the necessity and utility of information gathered through the form, it does not specify which areas of the form might particularly benefit from improvement. Clear examples or guidelines could encourage more targeted and useful feedback from stakeholders.
The IRS provides an estimate of the burden of completing the form—420 annual respondents with each spending approximately 48 minutes—but does not disclose the methodology behind these estimates. This lack of transparency might cause stakeholders to question the accuracy of these figures.
Moreover, while there is an assurance that tax return information will remain confidential as per legal requirements, there are no explicit procedures outlined for maintaining confidentiality within the comment process itself. This could result in hesitation among potential respondents worried about privacy and data security.
Lastly, the document mentions electronic or automated submission methods as a means to minimize the burden on respondents but fails to specify which, if any, current technologies are available. This omission might result in uncertainty and discourage potential responses from individuals and organizations who prefer or require digital submission options.
Impact on the Public
Broadly, this initiative reflects an ongoing effort by the IRS to refine its processes and reduce administrative burdens for taxpayers and businesses. By seeking public comment, the IRS aims to achieve a more efficient system that better meets the needs of all stakeholders.
For taxpayers, including businesses and not-for-profit organizations, this presents an opportunity to influence and improve how systemic issues are addressed by the IRS. Effective feedback could lead to more practical and user-friendly processes, thereby easing interactions with the IRS.
Impact on Specific Stakeholders
The outcome of this comment solicitation may positively affect tax professionals, businesses, and trade associations, who often deal with IRS forms and procedures. Their feedback could result in improved experiences and interactions with the IRS, particularly if systemic issues are effectively addressed and resolved.
Conversely, if the issues identified are not adequately addressed, the concerns could persist, negatively impacting stakeholders through continued inefficiencies or complexities in IRS processes. Furthermore, businesses and organizations that rely on clear and streamlined interactions with the IRS may be adversely affected if improvements are not realized.
Overall, while the notice holds the potential for significant positive impacts in refining IRS processes, the success of this initiative hinges on clear communication, transparency in the process, and the willingness of stakeholders to contribute substantively to the feedback process.
Issues
• The document mentions that comments should be sent to 'omb.unit@irs.gov' with a specific subject line; however, it may be unclear to some what specific format the email should follow, potentially leading to confusion.
• The notice invites comments to improve or evaluate the necessity and utility of the information collected but doesn't provide detailed examples or specific areas where feedback would be particularly beneficial.
• The estimated total annual burden hours and the estimated time per respondent are provided; however, the methodology behind these estimates is not explained, which could be seen as lacking transparency.
• There is a note on maintaining confidentiality of tax returns and return information according to 26 U.S.C. 6103, but no explicit instructions are given on how this will be ensured within the comment process.
• While the document mentions the potential use of electronic collection techniques to minimize burden, it does not specify any current electronic or automated options available, which may leave respondents uncertain about those processes.