There are many administrative problems that would take another study to review completely. The following are particular problems that affect division operations that ultimately determine how taxpayers are treated.

The Collection Division resists major internal policy changes. Recent major changes in IRS policies and procedures were made only after either congressional hearings, the completion of the 1976 Administrative Conference study, or the issuance of an audit report by the General Accounting Office (GAO). GAO has recognized deficiencies that national office personnel have been aware of for years, but they deliberately ignored them until they were discovered by the GAO.

There is a serious lack of control in the decentralization of the structure. The national office is not sufficiently controlling the regional offices, who are not sufficiently controlling the districts, who are not sufficiently controlling the group managers. In other government agencies, employees are allowed to conduct evaluations of their managers. These evaluations are conducted by an outside testing organization which then makes follow-up reports. If the IRS implemented this evaluation process in the field, the group manager would be more responsive to concerns of the national office, particularly if the evaluation process were used to identify managers who violate policies and procedures.

Chiefs of district collection divisions are not always rotated from time to time. One particular chief of a mid-Atlantic district Collection Division has been there for over 15 years. His rigid philosophy of collection is imparted to every revenue officer in his district. It is no accident that his district is in the top five nationwide in frequency of levies and seizures. Long tenure results in an inability to adapt to changes and a perpetuation of old philosophies that lead to harassment and other abuses of taxpayers rights.

All IRS policies and procedures are recorded in the Internal Revenue Manual (IRM). Part five of the IRM applies to the Collection Division. In 1979 the IRS computerized the printing and distribution of the IRM to make it cheaper and easier for employees to have their own manual. Some districts still refuse to issue a manual to every employee. For example, the Baltimore district issues one manual to the group manager, who keeps it in his office. Updates are en(erred by the manager's secretary. How is the field employee supposed to follow national office policy when he does not have his own manual? The inconvenience of having only one manual in an office with 15 employees is obvious. No one learns the details of how the job should be performed. The argument that some districts use against issuing individual manuals is that it takes too much time for an employee to keep his manual updated, (read another way: it takes away valuable time that could be used for making seizures) and that many employees don't keep their manuals updated anyway(This argument ignores the idea that they would if they were required to). Part five of the IRM is over 5,000 pages long. How an employee is supposed to research, learn, and follow such extensive guidelines with an inaccessible manual defies rational explanation.

As a course developer in the national office who was responsible for the national revenue officer training program, I tried to require that a manual be distributed to every new recruit joining the IRS staff. I even put manual reading assignments into the basic course. But I received a lot of resistance from various field managers. They contended it was a violation of their managerial prerogative to not have manuals for each employee. Several districts even placed orders with the national office for each employee but then sent a large number of them to the warehouse. This was probably done to disguise their true policy on manual subscriptions. The national office was led to believe that every employee was receiving a subscription when in fact that was not true.

To date, the national office has not required that a manual subscription be issued to each employee. This is clear evidence of the national office's lack of control over field activities. If the national office continues to feel it is not their responsibility to tell the field how to manage, then they are closing their eyes to the mission of the IRS and ignoring how inconsistent application of the tax laws adversely affects voluntary compliance.

The goals of the national office are contradictory to those of the districts. The goal of the national office is to "collect the revenue" and "protect the government's interest." The goals of the districts are to "close cases" and "project a firm enforcement image." The revenue officer has a wide array of tools to use to do his job. Not only can he negotiate installment agreements, file tax liens, and conduct seizures, he can also negotiate compromises, initiate litigation, make transferee assessments, and make use of bonds, mortgages, and escrow arrange meets. When the districts decide that closing the case to build statistics is more important than collecting the revenue, they are being irresponsible and derelict in their obligations.

As an example of this philosophy, the GAO reported that a tax account with a $58,000 delinquency was deemed uncollectible and all collection action suspended even though the taxpayer had over $40,000 equity in his home, over $5,000 cash surrender value in his life insurance policies, and $4,500 in cash. Another tax account with a $32,500 liability was deemed uncollectible even though the taxpayer's financial statement showed that he had equity of $22,000 in rental property and $21,000 in his residence. Cases reported uncollectible create a statistical "closure" even though no revenue is collected.

In the above two cases, perhaps the IRS did not seize the property due to a technical or legal reason (e.g., the property could have been jointly owned but the liability separately assessed). Nonetheless, the IRS had other collection alternatives they could have considered. In the GAO report, these same two taxpayers submitted offers to compromise their liability. The first taxpayer offered $28,000 to compromise the $58,000 liability, and the second taxpayer offered $20,000 on his $32,000 liability. Whereas in those two cases the IRS would have collected $48,000 on $90,000 worth of delinquent taxes. the total actually collected was less than $100.

Contradictory goals and objectives are manifested in another way. The national office has made it easy to enter into installment agreements (the GAO thinks it is too easy). The policy requires, however, that the taxpayer initiate the agreement proposal. Those who do not are subject to possible levy and seizure action by a revenue officer working for a "seizure-happy" enforcement-minded district group manager. This inconsistency puzzles taxpayers. At the national level, the IRS makes it easy for them, but at the district level they make it difficult.