National Taxpayer Advocate report to Congress released

On 1/14/15, Nina Olson, the National Taxpayer Advocate released her required annual report to Congress about problems with the tax system. As noted on the NTA website, the key parts of this 700+ page report are:

• Most Serious Problems
• Legislative Recommendations
• Most Litigated Issues
• Volume 2: TAS Research and Related Studies

 Some key points noted include:

• Tax law complexity (here + Executive Summary)
• The need to put taxpayer bill of rights into the Internal Revenue Code (here)
• Problems due to inadequate funding of the IRS (here + Executive Summary)
• The burden many taxpayers will face from Affordable Care Act provisions (here)
• The need to provide tax return assistance to low income individuals (here)

A few surprises (for me, so far - I haven't read it all yet)

• No mention of any need to modify Section 330 of Title 31 to allow the IRS to regulate all return preparers. The NTA was one of the first offices to call for such regulation years ago. It was noted in the 2013 report.
• No mention of the continued low level of binding guidance issued by the IRS while we instead get lots of FAQs, Chief Counsel Advice memorandums and information letters. The NTA has noted this issue before though.
• Failure of the IRS since 2003 to issue its required annual tax law complexity report to Congress (details here).
• One of the top litigated issues for the past year was Section 469 on passive loss limitations with 28 opinions between 6/1/13 and 5/31/14 (details here). The IRS won 23 of the 28 decisions.

I'll likely have more later.

What do you think?