SUPPORTING STATEMENT
(Form 911) Request for Taxpayer Advocate Service Assistance
(And Application for Taxpayer Assistance Order)
OMB #1545-1504
CIRCUMSTANCES NECESSITATING COLLECTION OF INFORMATION
Form 911, Request for Taxpayer Advocate Service Assistance (and Application for Taxpayer Assistance Order), is used by taxpayers (or representative) to apply for relief from a significant hardship which may have already occurred or is about to occur if the IRS takes or fails to take certain actions.
As part of the Technical and Miscellaneous Revenue Act of 1988 (TAMRA), the “Omnibus Taxpayer Bill of Rights” amended subchapter A of chapter 80 of the 1986 Code by adding Section 7811 “Taxpayer Assistance Orders” to provide that the Taxpayer Ombudsman (Taxpayer Advocate) and Taxpayer Advocate Service may issue Taxpayer Assistance Orders to stop or change IRS actions that cause significant hardship to taxpayers. IRS Form 911 is the form taxpayers use when applying for a Taxpayer Assistance Order.
USE OF DATA
Based on the information provided on Form 911, the IRS Taxpayer Advocate Service will decide whether the taxpayer is suffering or about to suffer a significant hardship. If there is a significant hardship, the Taxpayer Advocate Service decides whether the IRS action should be changed.
USE OF IMPROVED INFORMATION TECHNOLOGY TO REDUCE BURDEN
IRS has no plans at this time to offer electronic filing because of the low volume compared to the cost of electronic enabling.
EFFORTS TO IDENTIFY DUPLICATION
The information obtained through this collection is unique and is not already available for use or adaptation from another source.
5. METHODS TO MINIMIZE BURDEN ON SMALL BUSINESSES OR OTHER SMALL ENTITIES
The collection of information requirement will not have a significant economic impact on a substantial number of small entities.
CONSEQUENCES OF LESS FREQUENT COLLECTION ON FEDERAL PROGRAMS
OR POLICY ACTIVITIES
If the Internal Revenue Service (IRS) did not collect this information, federal programs or policy activities could result in taxpayers reporting an increase of significant hardships in order to change or prevent and IRS action.
7. SPECIAL CIRCUMSTANCES REQUIRING DATA COLLECTION TO BE INCONSISTENT WITH GUIDELINES IN 5 CFR 1320.5(d)(2)
There are no special circumstances requiring data collection to be inconsistent with Guidelines in 5 CFR 1320.5(d)(2).
8. CONSULTATION WITH INDIVIDUALS OUTSIDE OF THE AGENCY ON AVAILABILITY OF DATA, FREQUENCY OF COLLECTION, CLARITY OF INSTRUCTIONS AND FORMS, AND DATA ELEMENTS
In response to the Federal Register notice dated June 12, 2018 (83 FR 27373), we received no comments during the comment period regarding Form 911.
9. EXPLANATION OF DECISION TO PROVIDE ANY PAYMENT OR GIFT TO RESPONDENTS
No payment or gift has been provided to any respondents.
ASSURANCE OF CONFIDENTIALITY OF RESPONSES
Generally, tax returns and tax return information are confidential as required by 26 USC 6103.
JUSTIFICATION OF SENSITIVE QUESTIONS
A privacy impact assessment (PIA) has been conducted for information collected under this request as part of the “Taxpayer Advocate Management Information System” and a Privacy Act System of Records notice (SORN) has been issued for these systems under IRS 00.003 – Taxpayer Advocate Service and Customer Feedback; IRS 34.037 - IRS Audit Trail and Security Records System. The Internal Revenue Service PIA’s can be found at https://www.irs.gov/uac/Privacy-Impact-Assessments-PIA.
Title 26 USC 6109 requires inclusion of identifying numbers in returns, statements, or other documents for securing proper identification of persons required to make such returns, statements, or documents and is the authority for social security numbers (SSNs) in IRS systems.
ESTIMATED BURDEN OF INFORMATION COLLECTION
The burden estimate is as follows:
Authority |
Description |
# of Respondents |
#Responses per Respondent |
Annual Responses |
Hours per Response |
Total Burden |
Sec. 7811 |
Form 911 |
93,000 |
1 |
93,000 |
.50 |
46,500 |
Total |
|
93,000 |
|
93,000 |
.50 |
46,500 |
ESTIMATED TOTAL ANNUAL COST BURDEN TO RESPONDENTS
To ensure more accuracy and consistency across its information collections, IRS is currently in the process of revising the methodology it uses to estimate burden and costs. Once this methodology is complete, IRS will update this information collection to reflect a more precise estimate of burden and costs.
ESTIMATED ANNUALIZED COST TO THE FEDERAL GOVERNMENT
The Federal government cost estimate is based on a model that considers the following three cost factors for each information product: aggregate labor costs for development, including annualized start up expenses, operating and maintenance expenses, and distribution of the product that collects the information.
The government computes cost using a multi-step process. First, the government creates a weighted factor for the level of effort to create each information collection product based on variables such as; complexity, number of pages, type of product and frequency of revision. Second, the total costs associated with developing the product such as labor cost, and operating expenses associated with the downstream impact such as support functions, are added together to obtain the aggregated total cost. Then, the aggregated total cost and factor are multiplied together to obtain the aggregated cost per product. Lastly, the aggregated cost per product is added to the cost of shipping and printing each product to IRS offices, National Distribution Center, libraries and other outlets. The result is the Government cost estimate per product.
The government cost estimate for this collection is summarized in the table below.
Product |
Aggregate Cost per Product (factor applied) |
|
Printing and Distribution |
|
Government Cost Estimate per Product |
Form 911 |
5,000 |
+ |
0 |
= |
5,000 |
Instructions 911 |
|
|
|
= |
|
Grand Total |
5,000 |
|
|
|
5,000 |
Table costs are based on 2016 actuals obtained from IRS Chief Financial Office and Media and Publications |
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* New product costs will be included in the next collection update. |
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REASONS FOR CHANGE IN BURDEN
There are no changes being made to this form at this time. IRS is making this submission for renewal purposes.
PLANS FOR TABULATION, STATISTICAL ANALYSIS AND PUBLICATION
There are no plans for tabulation, statistical analysis and publication.
REASONS WHY DISPLAYING THE OMB EXPIRATION DATE IS
INAPPROPRIATE
IRS believes that displaying the OMB expiration date is inappropriate because it could cause confusion by leading taxpayers to believe that the form sunsets as of the expiration date. Taxpayers are not likely to be aware that the Service intends to request renewal of the OMB approval and obtain a new expiration date before the old one expires.
EXCEPTIONS TO THE CERTIFICATION STATEMENT
There are no exceptions to the certification statement.
Note: The following paragraph applies to all of the collections of information in this submission:
An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unlessthe collection of information displays a valid OMB control number. Books or records relating to a collection of information must be retained as long as their contents may become material in the administration of any internal
revenue law. Generally, tax returns and tax return
information are confidential, as required by 26 U.S.C.
6103.
| File Type | application/msword |
| Author | TQ1FB |
| Last Modified By | SYSTEM |
| File Modified | 2018-10-02 |
| File Created | 2018-10-02 |