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Tax Resolution Stats - By the Numbers: 2026 Tax Resolution Statistics Every Tax Pro Should Know

By the Numbers: 2026 Tax Resolution Statistics Every Tax Pro Should Know

A data-driven look at IRS collections, enforcement, and taxpayer debt as the agency operates with one of its smallest workforces in recent memory.

 

If you work in tax resolution, 2026 already feels different. The IRS workforce is sharply smaller, overall telephone service deteriorated during the 2026 filing season, and automated tools continue to play a larger role in tax administration. Those shifts are reflected in federal data.

 

We pulled the numbers from the IRS itself, the Government Accountability Office (GAO), the Treasury Inspector General for Tax Administration (TIGTA), and the National Taxpayer Advocate to paint an accurate picture of where things stand. Here’s what the 2025–2026 data shows, and what it means for tax professionals helping clients resolve tax debt heading into 2027.

 

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The Headline: A Shrinking IRS Is Managing More Than $540 Billion in Unpaid Assessments

$540.3 billion: that’s the total unpaid tax assessments the IRS reported as of September 30, 2025, according to GAO’s audit of the IRS’s FY2025 financial statements. That figure breaks into three categories under federal accounting rules: $361.3 billion in Federal Taxes Receivable (taxpayer-agreed amounts that already include penalties and interest, not just tax alone), $86.1 billion in Compliance Assessments the IRS has proposed but hasn’t secured taxpayer agreement on, and $92.8 billion in Write-Offs the agency doesn’t expect to collect. GAO notes the IRS itself estimates only about 19.5% of delinquent receivables are realistically collectible.

 

For a more collection-specific view, the FY2025 IRS Data Book shows 13,112,485 taxpayer delinquent accounts in ending inventory carrying $211.5 billion in assessed tax, penalties, and interest. The account count fell from 14.9 million at the beginning of FY2025, while the balance increased from $208.4 billion to $211.5 billion. That distinction matters: total unpaid assessments declined year over year, while the balance attached to accounts still in delinquent-account inventory increased.

 

27%: that’s how much of its workforce the IRS lost in a single year. Per the National Taxpayer Advocate’s 2025 Annual Report to Congress, the agency started 2025 with roughly 102,000 employees and finished with about 74,000. Customer service staffing alone dropped 22%.

 

Put those two numbers side by side, and you have one of the defining tensions in tax resolution in 2026: more than $540 billion in unpaid assessments and a workforce 27% smaller than at the start of 2025. For resolution professionals, cases are moving through an agency with materially less staffing capacity.

 

Key Stats at a Glance

StatEarlierLatest availableSource
Total unpaid tax assessments$566B (as of 9/30/2024)$540.3B (as of 9/30/2025)GAO-26-107977
Taxpayer delinquent accounts14.9M beginning inventory; $208.4B balance (FY2025)13.1M ending inventory; $211.5B balance (FY2025)Data Book, Table 4-1
Taxpayer delinquency investigations2.05M beginning inventory (FY2025)3.23M ending inventory; 2.50M new investigations (FY2025)Data Book, Table 4-1
IRS workforce~102,000 (start of 2025)~74,000 (end of 2025), down 27%NTA 2025 Annual Report
OIC acceptance rate42% (FY2023) → 21.4% (FY2024)5,464 accepted / 38,797 received (14.1%), FY2025IRS Data Book, FY2025
Federal tax liens filed~157,000 est. (FY2022)214,000+ (FY2025), up 36% since FY2022Data Book, Table 4-1
Third-party levy notices requested313,792 (FY2024)339,137 (FY2025), up 8.1%Data Book, Table 4-1
IRS call answer rate25% (prior filing season)21% (2026 filing season), 14-min avg waitNTA FY2027 Objectives Report
Installment agreements$16.11B collected (FY2024)$17.88B collected; 3.16M new agreements (FY2025)IRS Data Book, FY2025

 

IRS Collections and Enforcement: Activity Continues Amid Staffing Cuts

Despite the staffing cuts, the IRS isn’t standing still. The FY2025 IRS Data Book shows the agency collected more than $5.3 trillion gross in the fiscal year and closed 497,621 audits, recommending $26.8 billion in additional tax.

 

The bigger structural story, though, is the tax gap: the difference between what’s owed and what’s voluntarily and timely paid. The IRS’s most recent estimate (Publication 5869, covering tax year 2022) puts the gross tax gap at $696 billion, with a net tax gap of $606 billion after late and enforced payments. The voluntary compliance rate sits at 85.0%. Notably, the IRS’s next scheduled update (tax year 2023 data) has been delayed, which the Tax Policy Center has flagged as a real transparency concern heading into 2026. We’re currently working with numbers that are already a few years old.

 

What this means for practitioners: FY2025 audit output was slightly lower than FY2024. The IRS closed 497,621 audits in FY2025, recommending $26.8 billion in additional tax, down from 505,514 audits and $29 billion in recommended tax in FY2024, according to the FY2024 and FY2025 IRS Data Books. Those aggregate totals show lower year-over-year audit output. They do not establish a broad change in exam selectivity or individual examiner behavior. The practical value remains clear: catching a notice early through transcript monitoring before the client’s case has progressed further.

 

Nonfiler inventory also moved sharply. The FY2025 IRS Data Book shows the IRS opened 2,501,667 taxpayer delinquency investigations during FY2025 and ended the year with 3,234,815 in inventory, up from 2,050,877 at the start of the year. A taxpayer delinquency investigation is opened when a taxpayer does not respond to an IRS notice of a delinquent return, so these figures measure IRS collection workload rather than unique taxpayers or an underlying nonfiling rate.

 

Offer in Compromise: FY2025 Accepted-to-Received Ratio at 14.1%

If you’ve had a client ask what the latest OIC data shows, the FY2025 numbers are notably weaker than FY2024 and FY2023.

 

According to the FY2025 IRS Data Book, the IRS received 38,797 Offers in Compromise and accepted 5,464 during fiscal year 2025. Dividing acceptances by offers received produces a 14.1% same-year ratio, down from 21.4% in FY2024 and roughly 42% in FY2023. Because offers accepted in a fiscal year are not necessarily the same offers received that year, this figure should not be treated as a taxpayer’s individual probability of acceptance. The ratio has declined for two consecutive years.

 

For historical context, a 2018 IRS study cited by the Taxpayer Advocate Service found that in cases where offers were rejected, the IRS ultimately collected more than the taxpayer had originally offered in 71% of cash-offer cases and 66% of deferred-offer cases. In other words, the study provides useful historical context, and that historical result does not predict the outcome of an individual OIC today.

 

Given the trendline, accuracy, eligibility analysis, and realistic offer amounts remain critical. The aggregate data does not show why the same-year ratio fell or whether IRS acceptance standards tightened. Build the strongest initial submission around the client’s facts, reasonable collection potential, and complete documentation rather than treating 14.1% as the client’s individual odds.

 

Installment Agreements Remain the Workhorse

While OIC gets the headlines, installment agreements are doing the heavy lifting. In FY2025, the IRS established 3,160,047 new installment agreements, ended the year with 4,870,810 agreements in inventory, and collected $17.88 billion from cases in installment agreement status. That compares with $16.11 billion collected from IA-status cases in FY2024.

 

The FY2025 Data Book confirms the shift toward self-service is continuing: taxpayers established or revised almost 1.8 million installment agreements online during the year, a channel the IRS is investing in as phone wait times climb (see below).

 

Under current 2026 rules, the IRS’s “Simple Payment Plan” now covers balances up to $50,000, and the agency estimates more than 90% of individual taxpayers qualify for a streamlined plan without full financial disclosure. For eligible clients who don’t need an OIC or CNC determination, the payment-plan process can be a simpler resolution path.

 

Liens, Levies, and Wage Garnishment: Enforcement Activity Is Climbing

This is where the large unpaid-assessment balance and smaller workforce intersect with rising lien activity, and the freshest published numbers are higher than many older sources still cite.

 

Per the FY2025 IRS Data Book, the IRS filed more than 214,000 Notices of Federal Tax Lien in fiscal year 2025: up 9% from FY2024 and up 36% since FY2022. Tax Policy Center’s Daily Deduction reported on the increase in July 2026, citing the same Data Book Table 4-1 figures. The FY2025 total confirms that the increase continued beyond FY2024, when the IRS filed 196,996 NFTLs, up from 179,019 in FY2023.

 

Levy activity also increased. Table 4-1 shows 339,137 notices of levy requested on third parties in FY2025, up from 313,792 in FY2024, an increase of about 8%. This measure includes levies requested through the Automated Collection System and Field Collection programs; it is broader than wage levies alone.

 

Worth flagging to clients: a Notice of Federal Tax Lien does not require assignment to a Revenue Officer. IRS procedures allow ACS staff to make an NFTL filing determination and systemically request an NFTL through the Automated Lien System. Filing is not purely automatic, however: IRS procedures require a filing determination and provide criteria for filing, deferring, or not filing. Because ACS accounts may not have an assigned Revenue Officer, practitioners should not assume a live caseworker will intervene before an NFTL is filed.

 

Unlike private creditor garnishments, IRS wage levies aren’t capped at a percentage of income. The exempt amount is determined under IRS rules using the standard deduction and an amount tied in part to dependents. The exemption tables vary by filing status, number of dependents, and pay period, and are published annually in IRS Publication 1494. For 2026, those exemption tables are worth having on hand for every intake conversation, because clients are frequently surprised by how little of their paycheck is protected once a levy is in place.

 

Taxpayer Service Is the Real Bottleneck

If your practice has felt more friction dealing with the IRS this year, the data backs that up in stark terms.

 

The National Taxpayer Advocate’s FY2027 Objectives Report notes that during the 2026 filing season, the IRS received 48.1 million calls but telephone assistors answered only 9.9 million of them (21%), with an average hold time of 14 minutes. That’s a step backward from the prior season, when the IRS answered 12.4 million calls (25%) with an 8-minute average wait.

 

That 21% figure is enterprise-wide and masks large differences by line. Through April 18, 2026, customer service representatives answered 72% of Practitioner Priority Service calls with an average hold time of 8 minutes. The Automated Collection System line was at 55% with a 19-minute average hold, while the Installment Agreement/Balance Due line was at 31% with a 45-minute average hold. The IRS also replaced the former Accounts Management Level of Service metric with the Assistor Service Rate in 2026.

 

The takeaway for practitioners is that phone access varies significantly by line. Enterprise-wide figures should not be treated as the experience on every practitioner or collection line.

 

Penalties and Abatement: A Program in Transition

The IRS Data Book, Table 4-2 (formerly Table 28) shows the IRS assessed roughly 50.7 million civil penalties totaling $84.1 billion in FY2024, and abated nearly 6.5 million penalties totaling about $75.2 billion. The scale of abatements shows that reversals and reductions are a routine part of penalty administration. Still, the aggregate total includes multiple reasons for abatement and should not be read as a success rate for taxpayer requests.

 

And the mechanics are changing. The IRS has announced it’s phasing out the familiar First-Time Abate (FTA) program in favor of an automated “Automatic Exemption from Penalty” (AEP) system, beginning in summer 2026 and fully replacing FTA for returns due on or after January 1, 2027. Firms that lean on FTA as a standard playbook move should start building AEP into their process now, before the transition is complete.

 

The Funding Story Behind the Staffing Cuts

The 27% workforce reduction didn’t happen in a vacuum. TIGTA reports that Inflation Reduction Act enforcement funding was cut to $3.8 billion after a series of rescissions, and the IRS’s original $79.4 billion IRA allocation had shrunk to roughly $26 billion by January 2026. In total, $53.5 billion in IRA funding was rescinded: $41.8 billion from enforcement and $11.7 billion from operations support, alongside a deferred-resignation program that saw 21,646 employees leave.

 

The Budget Lab at Yale projects these staffing reductions could cost the federal government nearly $600 billion in lost revenue over 2026–2035 (a projection, not a certainty, but a meaningful signal of where enforcement capacity is headed).

 

The AI Pivot: More Automation, Less Oversight Capacity

Separately, among IRS technology efforts, the focus has increasingly been on artificial intelligence and machine learning, and the scale of that shift is now documented. According to a March 2026 GAO report, the IRS had 126 active AI use cases as of June 2025, up from just 10 in August 2022. The use cases span audit selection, fraud detection, income matching, and taxpayer-facing tools like the phone voicebots covered above.

 

Two things complicate that headline number, and both tie back to the staffing story. First, 61% of those use cases (77 of 126) were still in development, not yet operational, as of the same June 2025 snapshot. Second, the unit doing much of the building lost ground at the worst possible time: GAO found the IRS’s Research, Applied Analytics and Statistics group lost 63 employees who had been working full- or part-time on AI, part of the broader 2025 reduction. GAO’s actual finding is less flattering than the headline count suggests: the IRS is expanding AI use with no workforce plan to support it, more than a quarter of its AI use cases lacked documentation of what they’re supposed to accomplish, and no single office manages AI investment across the agency. GAO issued eight recommendations; the IRS agreed to all eight.

 

A May 2025 TIGTA report examined how the IRS uses AI to select returns for examination and found high no-change rates (audits that close with no additional tax owed), particularly among large partnership exams. TIGTA recommended incorporating examination performance results into monitoring and continuously refining AI classification and return-selection models. The report also found the IRS did not have sufficient processes to show whether implemented AI models outperform prior methods or achieve their intended objectives.

 

What this means for practitioners: IRS is using AI in compliance and fraud-detection work, including risk scoring and recommendations for audit or investigation, while watchdogs have identified gaps in model evaluation and agency-wide AI governance. That supports a cautious conclusion: practitioners should expect more AI-assisted compliance activity, but the available reports do not establish that collection notices are being generated by inadequately validated models.

 

Small Business Exposure: ERC Cleanup Isn’t Finished

For firms with small-business clients, the Employee Retention Credit remains an active compliance issue in 2026. A February 2026 GAO report found the IRS had processed nearly 5 million ERC claims as of June 2025. About 83% of ERC refund dollars, roughly $235 billion, were issued from 2022 through June 2025, well after the pandemic-era eligibility period ended. Under the One, Big, Beautiful Bill, refunds are now barred after July 4, 2025 for third- and fourth-quarter 2021 claims filed after January 31, 2024. Claims filed on or before January 31, 2024 are not subject to that restriction. If you have clients with pending or previously filed ERC claims, this remains an active compliance area.

 

Separately, tax gap data compiled by the Bipartisan Policy Center shows individual nonfiling contributes an estimated $53 billion to the overall gap, with another $9 billion from self-employment tax nonfilers, underscoring that nonfiling and self-employment tax remain meaningful components of the tax gap.

 

Identity Theft and Scams: Up Sharply

The FBI’s Internet Crime Complaint Center reported more than 1,000 tax-related identity theft complaints in the year ending April 2025, a 26% increase year-over-year. The IRS’s Security Summit separately reported nearly 300 data breaches affecting as many as 250,000 taxpayer records in just the first half of 2025.

 

The IRS’s 2026 “Dirty Dozen” list, released in March, continues to flag OIC “mills” (firms that make unrealistic promises about settling debt for pennies on the dollar) alongside newer threats like AI voice-cloning scams. It’s a useful, client-facing reminder that legitimate resolution work is defined by realistic expectations, not marketing promises.

 

What This Means Going into 2027

Pulling the data together, a few themes stand out for anyone doing resolution work this year:

  • The unpaid-assessment balance remains large while IRS staffing has fallen sharply. $540.3 billion in total unpaid assessments sits against a roughly 74,000-person workforce. However, total unpaid assessments declined from $566 billion in FY2024 to $540.3 billion in FY2025. Within Collection, taxpayer delinquent-account inventory ended FY2025 at 13.1 million accounts carrying $211.5 billion in assessed tax, penalties, and interest.
  • Collection and examination measures moved differently. NFTL filings are up 36% since FY2022. Audit closures and total recommended additional tax were slightly lower in FY2025 than FY2024. Those aggregate figures show diverging trends, but they do not establish that the IRS is deliberately substituting collection tools for examination work. Third-party levy notices requested also rose from 313,792 in FY2024 to 339,137 in FY2025.
  • Phone service is uneven across IRS channels. Enterprise-wide, customer service representatives answered 21% of calls during the 2026 filing season, but Practitioner Priority Service answered 72% with an 8-minute average hold through April 18. The line used matters for practitioner experience.
  • Two programs are mid-transition. The shift from FTA to the automated AEP penalty-relief system, and the ERC compliance wind-down, both require active attention rather than “wait and see.”
  • The same-year OIC accepted-to-received ratio has fallen for two consecutive years. 42% (FY2023) to 21.4% (FY2024) to 14.1% (FY2025). This is a meaningful trend for client conversations, but it is not the same as an individual taxpayer’s probability of acceptance.
  • Fraud and identity theft risk is climbing too. Tax-related identity theft complaints rose 26% year-over-year, and nearly 300 data breaches exposed up to 250,000 taxpayer records in just the first half of 2025, another reason client-side verification and security hygiene belong in the conversation alongside collection strategy this year.
  • IRS AI use has expanded amid documented governance and workforce gaps. 126 active AI use cases were in the inventory as of June 2025, up from 10 in 2022, while GAO found no agency-wide workforce plan and incomplete documentation for more than a quarter of the use cases. Those findings warrant attention as the IRS expands AI-supported processes.

 

Taxpayers navigating this environment face a mixed picture: some collection activity is up, some examination measures are down, and access to live assistance varies significantly by channel. For complex resolution matters, accurate records, timely responses, and professional representation are especially valuable.

 

Where This Data Meets Tax Resolution Casework

The FY2025 OIC figures and 2025 workforce reductions reinforce the value of building cases from current account data and accurate calculations. Tax Resolution Management inside IRS Solutions® pulls a client’s full IRS position and models the OIC and Installment Agreement math against Internal Revenue Manual standards before you submit.

See how it works: Tax Resolution Management

 

Quick Answers

What is the latest IRS Offer in Compromise acceptance figure?

In fiscal year 2025, the IRS received 38,797 Offers in Compromise and accepted 5,464, a same-year ratio of 14.1%, according to the IRS Data Book. That same-year ratio is down from 21.4% in FY2024 and roughly 42% in FY2023, but it is not a cohort-specific probability of acceptance for an individual offer.

 

How much has the IRS workforce shrunk?

The IRS started 2025 with about 102,000 employees and ended the year with about 74,000 (a 27% reduction), according to the National Taxpayer Advocate’s 2025 Annual Report to Congress.

 

How many federal tax liens does the IRS file each year?

The IRS filed more than 214,000 Notices of Federal Tax Lien in fiscal year 2025, up 9% from FY2024 and up 36% since FY2022, according to the IRS Data Book, Table 4-1.

 

How many third-party levy notices did the IRS request in FY2025?

The IRS requested 339,137 third-party notices of levy in FY2025, up from 313,792 in FY2024. The IRS Data Book, Table 4-1 says this measure includes requests through the Automated Collection System and Field Collection programs and is broader than wage levies alone.

 

How did IRS telephone service perform during the 2026 filing season?

During the 2026 filing season, IRS assistors answered 21% of 48.1 million enterprise-wide calls, with an average hold time of 14 minutes. Practitioner Priority Service performed better: through April 18, customer service representatives answered 72% of PPS calls with an average hold time of 8 minutes, according to the National Taxpayer Advocate’s FY2027 Objectives Report.

 

What is the latest reported amount of IRS unpaid assessments?

The IRS reported $540.3 billion in total unpaid assessments as of September 30, 2025. That accounting total includes $361.3 billion in gross Federal Taxes Receivable, $86.1 billion in Compliance Assessments, and $92.8 billion in Write-Offs. Separately, the IRS estimated only about 19.5% of delinquent receivables were collectible, according to GAO’s audit of the IRS’s FY2025 financial statements.

 

How many delinquent taxpayer accounts were in IRS inventory at the end of FY2025?

The IRS ended FY2025 with 13,112,485 taxpayer delinquent accounts carrying $211.5 billion in assessed tax, penalties, and interest. The account count declined from 14.9 million at the start of the year, even as the balance increased from $208.4 billion. See IRS Data Book, Table 4-1.

 

What IRS payment plan option is available for balances up to $50,000 in 2026?

Under current rules, individuals with $50,000 or less in assessed tax, penalties, and interest may qualify for the IRS’s Simple Payment Plan. The IRS says more than 90% of individual taxpayers qualify. In FY2025, taxpayers established or revised nearly 1.8 million installment agreements online, per the IRS Data Book. Across all channels, the IRS established 3.16 million new installment agreements and collected $17.88 billion from cases in installment agreement status during FY2025.

 

How much has the IRS’s use of AI grown?

The IRS had 126 active AI use cases as of June 2025, up from just 10 in August 2022, according to a March 2026 GAO report. GAO found that 61% of those use cases were still in development and that the IRS lacks a workforce plan to support its expanding AI use.

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