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TEGE EO Council Submits Comments in Response to IR-2023-171

04/01/2024 4:18 PM | Anonymous

Last September, in IR-2023-171 (Sept. 15, 2023), the IRS sought “comments and feedback on opportunities to expand and enhance tax certainty and issue resolution  . . . whether it’s by enhancing existing programs and tools or developing new ones.” The TEGE EO Council’s response, submitted Friday March 29, states the case for priority action in a 24-page report documenting an increasing number of software issues and pleading for application of the IRS’s Inflation Reduction Act funding toward solutions to efficiently serve the tax-exempt sector’s needs. The sought end—remediating both the unique disadvantages the tax-exempt sector is experiencing and alleviating the burden on IRS resources—is necessary to preserve and protect the reputation and vitality of the more than 1.8 million exempt organizations who serve our nation’s communities and citizens. 

The TEGE EO Council has a longstanding history of collaborative and productive dialogue with the IRS EO Division, including thrice-yearly EO Update sessions with EO Division Director Rob Malone and with his predecessors, Margaret Von Lienen and Tammy Ripperda. Across the past two years, that dialogue has included Councilmembers’ comments and queries relating to issues in the EO/BMF that interfere with organizations’ ability to, among other things, e-file and verify their status to/with third parties such as donors, banks, and state, local and federal agencies. Over this time period and as the result of multiple discussions, Council working groups concluded that the limitations of the IRS’s IT systems, exacerbated by underfunding of the IRS and understaffing of EO functions, have led to a unique impasse between the exempt organization sector and its regulatory overseer.

During these discussions, EO Director Malone and his colleagues have not only attentively fielded the Council’s concerns, but provided procedural recommendations and information connecting affected taxpayers with the frontline offices. The Council is exceptionally grateful for those ongoing efforts, which benefit the tax-exempt sector and the IRS.

The Council’s submission in response to IR-2023-171 is available here: 



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