In advance of Tax Day, Richard Rubin has a long read on enforcement dynamics in today’s leaner IRS. Lots on evolving taxpayer attitudes, the IRS’s plans for AI, and practitioners’ frustrations. Most notable is that these issues appear cross-cutting and pervasive. They stretch from low-income households to the most sophisticated businesses, from the EITC to the slow pace of advance pricing agreements. Link and excerpts, below the fold.

Richard Rubin, America’s New Tax Mantra: “The IRS Isn’t Going to Catch Me,” Wall St. J. (Apr. 12, 2026):

Audits of people with at least $10 million in income dropped 9% last year, and they are on track to decline another 39% this year. Partnership audits declined, reversing an attempt to scrutinize private-equity firms and other complex entities that have long bedeviled the government. . . .

Many tax lawyers favor a well-funded, competent IRS, because they prefer dealing with people who know the issues and resolve disputes efficiently for their clients. 

“Things are so bogged down because those appeals officers are so overloaded,” said Joshua Ungerman, a former IRS attorney now at Meadows Collier in Dallas. “It’s difficult to get your opportunity to make your case to the appeals officer because there’s so many people in front of you.”