With the government shut down and the IRS on a trajectory towards a slimmer workforce, the Treasury Department announced the creation of a new leadership position; current acting IRS Commissioner and Treasury Secretary Scott Bessent will continue in his interim role atop the tax agency.
Bisignano Joins IRS
On October 6, Treasury announced the appointment of Frank Bisignano as Chief Executive Officer. Bisignano, who also serves as Commissioner of the Social Security Administration (SSA), will oversee day-to-day IRS operations in a newly created position while continuing his SSA role.
Secretary of the Treasury Scott Bessent claimed Bisignano brings a strong record of driving growth and efficiency in both the private and public sectors. Bessent noted that the IRS and SSA share similar technological and customer service goals, making Bisignano a suitable choice for the new role.
“Under his leadership at the SSA, he has already made important and substantial progress, and we are pleased that he will bring this expertise to the IRS as we sharpen our focus on collections, privacy, and customer service in order to deliver better outcomes for hardworking Americans,” Bessent said.
Bisignano is the 18th Senate-confirmed Commissioner of the SSA and has more than four decades of experience in financial institutions and technology companies, including leadership roles at Fiserv, First Data, and J.P. Morgan Chase.
Treasury did not immediately respond to Checkpoint’s request for further comment.
Agency in Flux
Abbey Garber, a former IRS Chief Counsel attorney now with Holland & Knight, described the agency’s current state as fluctuating, citing “constant turnover” in leadership and changes in budget levels. “These are obviously unprecedented times,” Garber told Checkpoint, noting that the agency has had seven commissioners in a short period.
Garber said the IRS has lost about 25,000 employees since beginning the year with approximately 100,000 employees. This is due to a mix of voluntary resignations and government-wide reductions in force since the Trump administration took office in January.
But the IRS is accustomed to needing to adapt to changes in its overall operating capacity. “The IRS went through budget cuts … for years and years and has always had to prioritize and figure out how they’re going to manage the funds they have,” he said.
Delays in tax guidance could be expected, especially during the shutdown. Garber explained that slow guidance rollouts create gaps in the implementation of major legislation like the One Big Beautiful Bill Act (OBBBA; P.L. 119-21) signed July 4.
Garber agreed there may be an uptick in tax litigation in the coming years as a result of the complexity arising from the new law. But it remains to be seen how the Trump administration’s changes to the IRS will impact audit selection demographics and rates.
The IRS’ reliance on technology and automation has increased as staffing has declined, which the administration has said is intentional. Garber cautioned that technology cannot fully replace human expertise, especially when errors occur. According to Garber, automation can make certain things easier, but there should always be a human element in the taxpayer experience.
He illustrated a scenario in which a taxpayer is subject to a possible levy as part of automated collection procedures that is sent in error. For this taxpayer, there is no assessment against them, but there is also “no human being” to call. This would be “a mistake” if the IRS were to phase out live support representatives, said Garber.
“That’s a problem” that should be considered now while the agency gears up for next tax filing season. With tax season now just a few months away, much prep work is needed to update IRS systems to reflect the OBBBA.
Surviving the Shutdown
The American Institute of Certified Public Accountants (AICPA) had called for the IRS to announce its contingency plan for a potential government shutdown in a September 29 letter to Bessent. The AICPA recommended that the agency retain a plan similar to the previous year, which kept all IRS employees working.
If feasible, the AICPA urged the government to retain more essential IRS employees during the extended and upcoming filing season than in prior shutdowns.
“As critical stakeholders and partners with the IRS, we should have the opportunity to provide feedback on the IRS’s contingency plan and to adequately advise taxpayers on the potential consequences of a shutdown,” the AICPA stated.
The organization expressed concern that the shutdown will affect the timely processing of extended 2024 tax returns, tax-exempt organization returns, and expatriate tax returns.
The AICPA also noted that operating with a reduced workforce during a shutdown could strain both taxpayers and practitioners, disrupting payment and refund processing, as well dispute resolution.
The IRS indicated in its Fiscal Year 2026 Lapsed Appropriations Contingency Plan that due to supplemental appropriations from the Inflation Reduction Act, the agency did not expect a lapse in appropriations on October 1. All IRS employees are classified as “exempt” under the plan, with their compensation funded by resources outside of annual appropriations.
As a result, all IRS functions — including return processing, taxpayer services, compliance, and enforcement — were expected to continue without interruption. However, the contingency plan only accounts for the first five business days of lapsed funding. The agencies plans now that the shutdown has entered its second week remain to be seen.
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