What TIGTA found
Fair collection practices. TIGTA identified 32 potential Fair Tax Collection Practices violations between July 1, 2024 and June 30, 2025, most involving contact with a represented taxpayer that bypassed their authorized representative. Half had been coded as other types of misconduct. Separately, IRS frontline managers flagged 735 potential violations involving communications with a represented taxpayer without the taxpayer’s consent, many when taxpayers called IRS collection lines themselves. These were not reported in the misconduct system as procedures require. TIGTA also found 51 potential Fair Debt Collection Practices Act violations and 5 potential Fair Tax Collection Practices violations by private collection agency employees.
Direct contact restrictions. In a separate review, TIGTA found Field Collection employees largely complied with a taxpayer’s right to suspend an interview to consult a representative. But interviews showed inconsistent understanding: 8 of 18 employees could not correctly explain procedures for taxpayer voicemails, 10 misstated procedures for taxpayer-initiated follow-ups, 5 did not know taxpayers have 10 business days to consult a representative, and 10 wrongly said audio recording of an in-person interview is not permitted.
The IRS partially agreed with the three fair collection recommendations and agreed with the training recommendation on direct contact.
What it means for your clients
- Get the power of attorney on file first. A Form 2848 recorded on the Centralized Authorization File (it shows as TC 960 on the transcript) is what triggers the representative’s rights.
- Tell clients what to say if they call the IRS. When a represented taxpayer calls in, the employee must ask for consent to continue without the representative. Clients can decline and ask the IRS to contact their representative.
- Clients have rights in interviews. They can stop an interview to consult a representative and, with advance notice, audio record an in-person interview about the determination or collection of tax.
- Document bypasses. Note the date, the employee, and what was said. A bypass can be raised with the employee’s manager, and patterns are what TIGTA reviews each year.
Next Step services that fit
- Levy & Garnishment Defense. A representative standing between the client and collection, with the power of attorney on file.
- IRS Field Agent Representation (Business). Professional representation when a revenue officer is assigned.
- Stay Resolved. Ongoing monitoring so a represented client is not contacted around their representative.
Source: Treasury Inspector General for Tax Administration, FY 2026 Statutory Review of Potential Fair Tax Collection Practices Violations (September 23, 2026), and FY 2026 Statutory Review of Restrictions on Directly Contacting Represented Taxpayers (August 31, 2026), Report No. 2026-300-057 and 2026-300-048. Reports are available at tigta.gov.
This summary is for tax professionals and is general information, not tax or legal advice for a specific situation. Figures are as reported by TIGTA. Results for any client depend on their facts, documentation, and IRS discretion.