IRS Liaisons Issue Management Resolution System collects, vets, and works through feedback on national issues that are broad and systemic to improve IRS policies and procedures. If you have feedback regarding certain filing season issues, make contact immediately.
IRS Liaisons use the Issue Management Resolution System (IMRS) to collect, vet, and work through feedback on national issues that are broad and systemic (as opposed to specific and personalized) to improve IRS policies, processes, and procedures with the goal of reducing the burden on taxpayers, tax professionals, and the IRS. In short, it is to address issues that negatively affect tax administration. As PICPA’s IRS-approved IMRS representative, I collect issues and provide feedback from PICPA membership at the quarterly meetings of the IRS Liaison during the open forum. The IRS will accept only vetted issues to ensure that all appropriate research (answers not found using the IRS website or Internal Revenue Manual) and IRS processes were followed correctly. Only IRS Communications & Liaison (C&L) employees determine if an issue warrants elevation to IMRS staff who complete internal research, then elevate the issue to the appropriate IRS unit if found to be broad and systemic. IRS Liaisons track and report resolved issues to tax practitioner representatives, which could take six months or longer.
For the March 12, 2026, meeting, vetted issues are ready for presentation. However, if you send me an issue that dictates priority over the March issues, I may submit it in March instead of at the June meeting. IRS Liaison meetings are more frequent now, but they also have more attendees. So, when submitting an issue, it is critical to submit only vetted broad and/or systemic issues in a succinct form to our PICPA IRS Liaison Subcommittee. Since it is filing season, IRS wants the March meeting to focus on topics like Modern Payments (EO 14247-No Checks), mailed return/payments, new OBBBA provisions, using IRS online platforms like Tax Pro Account, Business Tax Account, IOLA, and IRS Document Upload Tool. I’d appreciate members’ feedback regarding these and other filing season issues.
It can be difficult to determine if an issue is broad and/or systemic (impacting a significant number of taxpayers). For example, representatives at the last meeting shared an issue they were experiencing, but it was not widespread within the local group. In that case, the IRS recommendation is to bring the issue directly to your local IRS Stakeholder Liaison who will begin the process of researching the issue and can reach out to other IRS Liaisons nationwide to see if it is widespread. Pennsylvania’s IRS Senior Stakeholder Liaison, Richard Furlong, has always been responsive to our members and continues to accept issues. He will continue to be a sort of early warning system on developing local issues, which may become large systemic issues over time. Issues that can’t wait for the quarterly meetings – such as ID theft/data breaches – should be sent immediately to Richard Furlong.
When it comes to certain ongoing IRS problems – such as long wait times, hang ups in the middle of talking with an agent, “courtesy” disconnects, or inexperienced or ineffective agents – the IRS and PICPA’s representatives need tax practitioners to submit all details regarding the problems. For example, tax practitioners should document the exact time, date, and duration of each call; the IRS agent(s) name with whom you spoke; badge identification number(s); and an explanation of the problem(s). Take accurate notes on everything you discuss, including all advice, instructions, and deadlines. Although IRS records these calls, without these details the IRS will be unable to follow up.
The IRS recently revised the IMRS structure. There are now five national regions that each hold quarterly meetings instead of the former individual state meetings. For the first meeting since the relaunch, IRS Liaisons asked representatives for feedback on OBBBA provisions – including tax on tips, tax on overtime, penalty relief for 2025, and updating withholding – as well as how to improve e-News for Tax Professionals to be more useful. Resolved national issues that were shared included erroneous CP161 letters primarily affecting Forms 1041 and 1120. As of Oct. 13, 2025, IRS adjusted accounts for safe harbor estimated payments so review affected client transcripts to verify corrections. IRS updated Direct Pay to allow 1040-ES payments to current and future years. In the future I will be sharing items permitted from each meeting in PICPA’s CPA Now blogs. You can sign up for weekly blog posting notifications.
Communicating with the IRS can be time-consuming and frustrating. I suggest you access resources such as AICPA’s Contacting the IRS FAQs, IRS Hotlines Quick Reference Chart, and IRS Penalty Abatement Templates for best practices to reach the correct IRS unit and resolve issues efficiently.
The Systemic Advocacy Management Systems (SAMS) is another resource practitioners can use to report issues that impact multiple taxpayers. The IMRS may encounter overlapping issues that were submitted through SAMS, which is overseen by the Taxpayer Advocate. The purpose of SAMS is like IMRS in that it serves as a formal channel for advocacy, allowing users to submit issues that may require systemic change in IRS systems, policies, and procedures, as well as taxpayer rights, burdens, fair treatment, and essential services. The primary difference between IMRS and SAMS is that if an issue elevates through IMRS, IRS employees will research it, author a short paper, then present it to the appropriate IRS unit. SAMS is an internet-based pathway that allows reporting to IRS, but it does not guarantee immediate action or resolution. Anyone can enter information into SAMS; whereas through IMRS, only an IRS C&L employee can elevate an issue. Practitioner representatives that have used SAMS gave it a positive review. When you report an issue at SAMS, you should receive an email confirming the Office of Systemic Advocacy received your submission. SAMS may contact you for clarification or ask for more examples, and will share your information in the advocacy efforts. However, it only informs you of an issue’s status once closed; IMRS provides issue tracking.
PICPA’s IRS Liaison subcommittee is part of the Federal Tax Thought Leadership Committee and is looking for volunteers to identify and/or evaluate issues to ensure they meet IMRS criteria and that all appropriate research is completed. IRS Liaison subcommittee members meet at least once a year with Richard Furlong and other tax authorities to prepare for PICPA’s Annual Q&A with IRS. However, the IRS invites only one or two representatives per professional organization to attend the IRS Liaison IMRS Regional Virtual Meetings and prohibits representatives from sharing its invites/links. IRS takes attendance at that meeting, and all uninvited attendees will be cut off.
If you need an IRS Stakeholder from a different region, although you may want to reach out to Richard Furlong first, the IRS website lists the general email for the IRS Stakeholder Liaison for all regions. Pennsylvania as well as Connecticut, Delaware, Massachusetts, Maryland, Maine, New Hampshire, New Jersey, New York, Rhode Island, and Vermont are listed as Richard’s region 2 (cl.sl.area.2@irs.gov). Pennsylvania is region 4 for IMRS meetings only.
Karen Facer-Mee, CPA, CGMA, is managing shareholder with Facer, Mee & Associates PC in Ivyland, Pa., and is chair of PICPA’s Federal Taxation IRS Liaison subcommittee. She is one of the founding organizers of PICPA’s Q&A with IRS Senior Stakeholder Liaison and panel of tax experts, and collaborates with practitioners all year to determine questions/issues that need resolving. Karen can be reached via email at karen@facermee.com or call (215) 355-4900.
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Statements of fact and opinion are the author's responsibility alone and do not imply an opinion on the part of the PICPA's officers or members. The information contained herein does not constitute accounting, legal, or professional advice. For actionable advice, you must engage or consult with a qualified professional.
