SOI--405 - Justification Statement

Request for Approval under the “Generic Clearance for the Collection of Routine
Customer Feedback” (OMB Control Number: 1545-1349)
TITLE OF INFORMATION COLLECTION:
Focus Group: “IRS Post-Filing: Processes and Taxpayer Representation”
PURPOSE:
In response to questions from a number of stakeholders, IRS Office of Research is developing an
Individual Post-Filing Burden model in order to better understand the current level of this burden and its
impact on tax administration. Based on the results of a pilot study, we have found that taxpayers are often
unable to distinguish the different levels of examination and collection, which limits their ability to
communicate their experiences with the post-filing process. Focus group sessions with tax professionals
who are experienced in providing taxpayer representation services will allow us to:
o Reflect post-filing processes as they occur in actual practice,
o Understand how to quantify post-filing burden from the perspective of taxpayers and their
representatives,
o Hear where post-filing processes are working well,
o Hear where post-filing processes can be improved,
o Better understand the role of the tax professional in the post-filing process, and
o Identify steps the IRS can take to help tax professionals better serve taxpayers in representation
engagements.
The IRS Nationwide Tax Forums, held annually in six locations across the country, provide an
opportunity for IRS Office of Research to conduct focus group sessions with practitioners who provide
taxpayer representation services. The information obtained will allow the IRS to better understand the
post filing process, how to improve the post-filing process to reduce taxpayer burden, and how the IRS
can assist tax professionals in providing high-quality, value-add representation services.
The objectives of each focus group meeting would be to gain insight and feedback on the current level of
post-filing burden and its impact on tax administration. IRS Office of Research plans to conduct these
focus groups at three of the six IRS Nationwide Tax Forums, during the period August 9, 2011 –
September 1, 2011.
DESCRIPTION OF RESPONDENTS:
Enrolled practitioners (EAs, CPAs, attorneys) who have at least three years experience providing taxpayer
representation services.
TYPE OF COLLECTION: (Check one)
[ ] Customer Comment Card/Complaint Form
[ ] Usability Testing (e.g., Website or Software
[X] Focus Group

[ ] Customer Satisfaction Survey
[ ] Small Discussion Group
[ ] Other: ______________________

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CERTIFICATION:
I certify the following to be true:
1. The collection is voluntary.
2. The collection is low-burden for respondents and low-cost for the Federal Government.
3. The collection is non-controversial and does not raise issues of concern to other federal agencies.
4. The results are not intended to be disseminated to the public.
5. Information gathered will not be used for the purpose of substantially informing influential policy
decisions.
6. The collection is targeted to the solicitation of opinions from respondents who have experience with
the program or may have experience with the program in the future.
Digitally signed by Sandy Lin
DN: cn=Sandy Lin, o, ou=RAS:R:
TAM, [email protected],
c=US
Date: 2011.05.25 12:39:25 -04'00'

Name:____Sandy Lin (RAS:OR:TAM)_________________________________
Sandy Lin
To assist review, please provide answers to the following question:
Personally Identifiable Information:
1. Is personally identifiable information (PII) collected? [ ] Yes [X] No
2. If Yes, is the information that will be collected included in records that are subject to the Privacy Act
of 1974? [ ] Yes [ ] No
3. If Applicable, has a System or Records Notice been published? [ ] Yes [ ] No
Gifts or Payments:
Is an incentive (e.g., money or reimbursement of expenses, token of appreciation) provided to
participants? [ ] Yes [X] No
BURDEN HOURS
Category of Respondent
Type 1 – Individuals (Tax practitioners,
screening step)
Type 1 – Individuals (Tax practitioner,
focus group step)
Totals

No. of
Respondents
150
36
186

Participation
Time
0.10 hrs
2 hrs

Burden
15 hrs
72 hrs
87 hrs

FEDERAL COST: The estimated annual cost to the Federal government is _$ 4,436. _____
Hotel at $200 for 4 nights………………………………………………… $ 800
Meals and Incidental Expenses of $64 for 3 full days and 2 travel days…..$ 288
Flight………………………………………………………………… ...… $ 720
Local Transportation……………………………………………………… $ 100
Subtotal travel cost per forum outside the DC area ………….……… $1,908
Total travel cost for one IRS staff to attend two forums…………..…………… $3,816
Local Travel for Washington DC National Harbor………………………$
40
Total estimated transportation for two IRS staff to attend local
forum…………………………………………………………………..……..$
80
Transcription cost for three 2-hour sessions……………………………..……………$ 540
Total estimated……………………………………………………………………..$ 4,436

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If you are conducting a focus group, survey, or plan to employ statistical methods, please provide
answers to the following questions:
The selection of your targeted respondents
1. Do you have a customer list or something similar that defines the universe of potential respondents
and do you have a sampling plan for selecting from this universe?
[ ] Yes [X] No
If the answer is yes, please provide a description of both below (or attach the sampling plan)? If the
answer is no, please provide a description of how you plan to identify your potential group of
respondents and how you will select them?
Attendees at three IRS Tax Forums will be screened for participation in the focus group session to be
conducted during the respective forum. In order to receive an invitation to participate in the focus group,
the individual must be an enrolled practitioner (EA, CPA, or attorney) who has at least three years of
experience providing taxpayer representation services.
Administration of the Instrument
1. How will you collect the information? (Check all that apply)
[ ] Web-based or other forms of Social Media
[ ] Telephone
[X] In-person
[ ] Mail
[ ] Other, Explain
2. Will interviewers or facilitators be used? [ X] Yes [ ] No
ATTACHMENTS
Appendix A – Schedule of IRS Tax Forums where focus groups will be held.
Appendix B – Recruiter’s Guide for the “IRS Post-Filing: Processes and Taxpayer Representation” Focus
Group. Each focus group will consist of 10-12 participants and be limited to 120 minutes in duration.
Appendix C – Moderator's Guide for the “IRS Post-Filing: Processes and Taxpayer Representation”
Focus Group. One moderator will facilitate each group and one will take notes. The sessions will also be
audio-taped to document notes for the report and then the tapes will be destroyed.
Appendix D – Section of Proposed Taxpayer Survey. The Moderator’s Guide includes high-level
questions seeking feedback from respondents. Information received from respondents will be considered
when developing the questions for the actual taxpayer survey to be conducted in FY2012.

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APPENDICES
Appendix A: Schedule for 2011 IRS Nationwide Tax Forums where “IRS Post-Filing: Processes and
Taxpayer Representation” focus groups will be held
City
San Jose, CA
Las Vegas, NV
Washington, DC National Harbor

Dates
August 9 – 11, 2011
August 16 – 18, 2011
August 30 – September 1, 2011

Appendix B: Recruiter’s Guide for the “IRS Post-Filing: Processes and Taxpayer Representation”
Focus Groups
One 120 minute focus group. Recruit 25 for approximately 10-12 to show up for each group.
Hello, my name is _______ and I am an employee of the Internal Revenue Service. The IRS is hosting a
series of focus groups across the U.S. to learn more about the current post-filing environment, such as
IRS examinations, appeals, and collections. I am recruiting approximately 12 tax preparers to participate
in one of these focus group discussions. The focus group will gather ideas and opinions from you.
Note: If the respondents are concerned about participating, tell them that the IRS specifically prohibits
you from revealing any information about them to the IRS or anyone else.
First, may I ask you some qualifying questions?
Question #1: Are you Circular 230 practitioner licensed to represent taxpayers in matters before the
IRS?
If the answer is “yes, Circular 230 practitioner” ask question #2.
If the answer is no, do not invite the person.
Question #2: (If Circular 230 practitioner) Do you have at least three years of experience providing
taxpayer representation services?
If the answer is yes, invite the participant.
If the answer is no, do not invite the person.
Invitation
We would like to invite you to participate in the focus group titled ‘IRS Post-Filing: Processes and
Taxpayer Representation with about 11 other people. Again, we want to hear your opinions, views and
ideas. The session should take about 2 hours and will be held on __(day)__ at __(time) __ in Room
__________.
Note: Read the Paperwork Reduction Act
The Paperwork Reduction Act requires that the IRS display an OMB (Office of Management and Budget)
control number on all public information requests. The OMB Control Number for this focus group is
1545-1349. Also, if you like, I can give you a name and address where you can send comments and
questions regarding this process or suggestions for making it simpler.

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Note: Read only if Person asks for address to send comments to:
Internal Revenue Service
Tax Products Coordinating Committee
SE:W:CAR:MP:T:T:SP
1111Constitution Ave. NW
Washington, DC 20224
Thank you and have a nice day. We look forward to meeting with you on (DATE) at (TIME)
Appendix C: Moderator's Guide for the “IRS Post-Filing: Processes and Taxpayer Representation”
POST-FILING: PROCESSES AND TAXPAYER REPRESENTATION
Focus Group Moderator’s Guide
Focus Group Dynamics: Up to 15 Circular 230 Tax Practitioners (EAs, CPAs, attorneys) who have at
least three years of experience providing taxpayer representation services. Participants may either be
employees of a tax preparation firm or self-employed. Representation services may or may not be the only
tax service provided by the tax professional.
Length: Two hours
A. Introduction 10 minutes
My name is _______________. I work in the IRS Research community and I’m the moderator for this
session. This is my co-moderator ______________.
The IRS Office of Research is currently developing a survey as part of an effort to gather more
information about the burden faced by individual taxpayers during post-filing processes. For the purposes
of our study, we are defining “post-filing” events as any taxpayer interaction with the IRS regarding a
previously filed tax return – for example, exams, appeals and collections.
The purpose of this discussion is to talk about your experiences assisting taxpayers through post-filing
processes. Your experience providing taxpayer representation services places you in the unique position
of being able to understand what a taxpayer faces when dealing with the IRS, as well as being familiar
with post-filing processes. Your participation today will help us improve the questions on the survey and
help us gain insight into what we are doing right, how we can improve post-filing processes, and how we
can assist you, the tax professional, in providing high-quality, value-added representation services. The
discussion will last approximately two hours.
FOCUS GROUP INTERVIEWING AND MODERATING
Before we start, let me ask how many of you have participated in a focus group before?
[IF SOME PEOPLE ARE NEW TO FOCUS GROUPS] For those of you who have not, let me explain.
Focus groups are a type of group interview, and they are designed to promote interaction among
participants for the purpose of eliciting a diversity of views, ideas, and opinions about the topic under
discussion.
We have some ground rules that I would like to go over:
•

Please talk one at a time and in a voice at least as loud as mine and avoid side conversations.
Please turn off any cell phones or beepers.
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•

My co-moderator and other observers in the room will be taking notes as well as recording this
session. The recording will only be used to assist with documenting this focus group session, and
then they will be destroyed.

•

During this discussion, please use first names only.

•

Because we want you to be frank and open with your responses, I want to assure you that all
comments in this room are strictly private— NO NAMES WILL BE USED IN OUR REPORT.

•

There will be no formal break; however, if you need to stretch, go to the restroom, or walk around
a little, please feel free to do so but please rejoin the group as quickly as possible. Your comments
are very important to us.

•

Most importantly, we’re here to get as many different opinions and experiences as possible. So,
not every person has to answer every question, but we do want to make sure everyone gets heard
today. Remember, there are no wrong answers. The goal of our focus group today is not so much
that the group reach an agreement, although it’s okay if that happens, but that you each say what’s
true for you – that’s why we’ve invited [NUMBER OF PARTICIPANTS] of you here today
instead of just one. So if you have a different experience or opinion, please let us know exactly
how you feel. And if you change your mind, that’s okay, too. Just let us know about it.

My job as your moderator is to:
•
•
•

Help guide the flow of conversation,
Make sure everyone’s comments are heard, and
Ensure that questions about various aspects of the topic are covered.

Also, please note that in the interest of time, there may be occasions where I may have to interrupt the
conversation in order to move on to another topic or set of questions.
We are required by law to report to you the OMB control # for this public information request. That
number is ________________.
Does anyone have any questions before we begin?
B. Warm Up 5 minutes
Let’s begin by getting to know each other a little better. Please introduce yourself to the group and tell us:
Note: Go around the table.
o Your first name,
o Whether you are an EA, CPA, or attorney,
o How long you’ve been providing representation services
o And are your representation services primarily for correspondence exams, office exams, field exams,
or collections.
C. Discussion Topics 100 minutes
Topic I: Post-filing Process in General (40 minutes)
1. First, I want to ask some general questions about clients.
Probes:

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a) At what stage in the process do your clients typically first seek your services for post-filing issues?
When they get the first letter? After they have tried to resolve the issue themselves? When a case
is at the Appeals level?
b) Are most of your representation clients new to your office, or are they your tax return clients?
c) What are the primary reasons why taxpayers seek assistance with IRS post-filing issues?
2. Now let’s talk about what happens during an IRS examination or audit. How do you interact with
clients and the IRS during an examination?
Probes:
a) What do you ask your client to do to prepare for an audit (gather materials, meetings, etc.)?
b) How many times do you typically meet or communicate with your client (in person, through
email, or on the phone)?
c) How many times do you typically meet or communicate with the IRS (in person, through
correspondence, or on the phone)?
d) [OPTIONAL:] Do you prepare written responses to letter audits? If so, do you sign these letters as
the taxpayer’s representative or does the taxpayer typically sign them?
3. Now let’s talk about what happens during an Appeal. How do you interact with clients and the IRS
during an Appeal?
Probes:
a) What do you ask your clients to do (gather materials, meetings, etc.) when a case is at the Appeals
level?
b) How many times do you typically meet or communicate with your client (in person, through
email, or on the phone)?
c) How many times do you typically meet or communicate with the IRS (in person, through
correspondence, or on the phone)?
4. Now let’s talk about Collections cases. How do you interact with clients and the IRS during
collections cases?
Probes:
a) What do you ask your clients to do (gather materials, meetings, etc.)?
b) How many times do you typically meet or communicate with your client (in person, through
email, or on the phone)?
c) How many times do you typically meet or communicate with the IRS (in person, through
correspondence, or on the phone)?
Topic II: The Tax Professional’s Role (10 minutes)
5. Now thinking about post-filing cases in general, how easy is it to interact with the IRS?
Probes:

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o What information, in addition to the information provided in the IRS notice, must be obtained
from the IRS in order to properly respond to a notice?
ƒ [OPTIONAL:] How easy is it to obtain this information?
o What could the IRS do to better assist you in representing your clients?
o [OPTIONAL:] Have you developed any special practices or “workarounds” that help you deal
with IRS personnel or to facilitate the post-filing process?
Topic III: Time Burden (10 minutes)
6. On average, how much direct time does it take you and your clients to resolve a case? (By direct, we
mean time you or your client spent actually working on a case, as opposed to wait- time).
Probes:
a) How much of this is your time? How much is your client’s time?
b) [OPTIONAL:] Which activities do you think taxpayers spend the most time on when dealing with
an audit? What about appeals? What about collections?
c) [OPTIONAL:] Which activities do you spend the most time on when dealing with an audit? What
about appeals? What about collections?
Topic IV: Cost Burden (10 minutes)
7. How do you typically charge for representation services?
Probes:
•

Does your tax practice include audit services in the tax preparation fee?

•

Are your fees for representation services based on a flat rate, an hourly rate, or a combination of
the two?

•

Do you have different fee schedules for tax clients vs. nonclients?

Topic V: Taxpayer Burden Survey (30 minutes)
Now we would like to show you a draft of a questionnaire that we plan to send to individual taxpayers,
asking them about the time and out-of-pocket costs that they spend on dealing with post-filing issues.
[SAY THE FOLLOWING WHILE YOU ARE HANDING OUT THE SURVEY] This survey will be
mailed to taxpayers and they will have the option to complete a hard copy and return it by mail, answer
the questions on the web, or over the telephone. The recipients will be specifically instructed not to ask a
tax professional for assistance in completing the survey.
Please take a few minutes to look over this survey, and then we will discuss your reactions to it.
1. What are your overall impressions of this survey?
2. During the survey, we ask the respondent to think about their post-filing experiences for a specific
tax year. Do you think the average person understands the phrase “tax year” and can answer
questions about their experiences related to a specific tax year?
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3. In question 6 we ask the respondent to report the number of times they did certain activities.
a) Do you think the numerical scale we used (1-2, 3-5, 6-10, 11 or more) is appropriate?
b) Do you think the average person would be able to remember the number of times they did
the listed activities?
c) Do you think the list of activities is appropriate?
4. Can you give us any suggestions on how to improve these questions or make them easier to
answer?
5.

[OPTIONAL:] In your opinion, is this a survey that someone like your typical client would be
able to complete?
a) [OPTIONAL] Which parts of the survey do you think will be the most difficult for the
average person to answer?

D. Closing 5 minutes
Are there any more comments or issues on the topics we’ve covered today that you’d like to discuss?
Thank you for all your help. Your ideas and opinions are very important to us. Your participation here
today is valuable and greatly appreciated.

Appendix D:
Individual Post-Filing Burden Survey Questions
Description of the Event
1. Which of the following IRS notices did you receive for tax year XXXX? [check all that apply]
A notice telling you that:
o You owed the IRS money
o You would be receiving a refund
o You needed to file a tax return
o You must send in additional information or documents to the IRS
o A Federal Tax Lien had been filed against you
o The IRS was about to seize some of your property
o The IRS made changes to your tax return, but did NOT require any action from you
o None of these. SKIP to Question 4
2. How many notices did you receive from the IRS for tax year XXXX?
o 1–2
o 3–5
o 6 – 10
o 11 or more
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o I did not receive any notices from the IRS for tax year XXXX
3. Which of the reasons below, if any, describe why you received one or more IRS notices? [check
all that apply]
o I needed to provide additional information
o My return was incomplete
o I made a mistake on my return
o I owed the IRS money
o My return was selected to be audited
o The IRS made a mistake
o I don’t know
o Other __________________________________________
4. Which of the following IRS actions did you experience for tax year XXXX? [check all that
apply]
o An audit by an IRS representative at an IRS office or at your home or business
o A lien
o A levy
o None of these
5. While resolving your post-filing issue or issues, did you do any of the following actions [check
all that apply]
o Send one or more documents to the IRS
o File an amended return
o Appeal an IRS decision
o Pay additional tax
o Request an IRS Installment Agreement
o Submit an Offer in Compromise
o Request a release of Federal Tax Lien
o Go to Tax Court
o I did not take any of these actions

Continued on next page

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Process/Activities
6. How many times did you do any of the following with regard to your post-filing issue or issues
for tax year XXXX?
None

1-2

IRS
Read IRS notices or
correspondence
Visit the IRS website
Obtain and/or read IRS publications
Talk with the IRS on the phone
Talk with the IRS in person
Write letters to the IRS
Third-party
Get advice or help from friends and
family
Send a letter (or email) to a
financial institution
Send a letter (or email) to a tax
professional
Talk to financial institutions on the
phone
Talk to a tax professional on the
phone
Meet with a tax professional
Other
Filling out additional forms
Review prior year’s
return/documents
Review submitted return
Perform calculations
Look for and gather receipts, pay
stubs, or other income and expenserelated documents
Obtain birth certificates, SSNs or
other official records
Submit documents (mail, email or
fax)
Visit non-IRS websites
Other
If other, please specify:

Continued on next page

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3-5

6 - 10

11 or more

Time
7. How much total time have you (and/or your spouse, relatives, or friends on your behalf) spent
resolving the matter?
a. ____Hours ____Minutes or _____None
b. How much of the time noted above was spent working with a tax professional, if any?
i. ___Hours ___ Minutes ____None ____ Not applicable
Money
8. How much out-of-pocket money in total have you spent to resolve the matter? (Do NOT include
any taxes paid, penalties, and interest).
a. $_______.00
b. None
9. How much of the money you reported in Question 8, if any, was paid to a tax professional?
a. $_____.00
b. None
c. I did not use a tax professional

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