The GAO Gave the IRS 26 Priority Fixes. The Agency Has Had Seven Different Leaders Since the Clock Started.

The Government Accountability Office — Congress’s nonpartisan auditor — sent its 2025 priority-recommendations letter for the Internal Revenue Service on September 26, 2025, publicly released November 17, 2025, and addressed to then-Acting IRS Commissioner Scott Bessent. The tally: 26 open priority recommendations, spanning agency transformation, tax-gap enforcement, the taxpayer experience, data security, and information reporting.

That 26 is worth doing the arithmetic on, because GAO shows its work: 30 priority recommendations were open as of June 2024; five were implemented in the year that followed, one was removed, and two new ones were added — 30 minus 5 minus 1 plus 2 equals 26. (An earlier circulating count put the figure at 27; the report’s own math lands on 26, and that is the number this page uses throughout.)

What makes this more than a bureaucratic scorecard is timing. The letter lands in the middle of the most volatile stretch of IRS leadership in decades — a stretch that includes a disbanded transformation office, a paused reporting requirement to Congress, and seven different commissioners or acting commissioners cycling through the agency’s top job since early 2025.

• 26 — open priority recommendations GAO says the IRS should implement, addressed to then-Acting Commissioner Scott Bessent · Source: GAO-25-108066
• 35 years — how long GAO's “Enforcement of Tax Laws” has sat on its government-wide High-Risk List — since 1990 · Source: GAO-25-108066; GAO-25-107743
• $80 billion — annual tax gap GAO attributes to sole proprietors alone · Source: GAO-25-108066
• $32.40B — refund interest the IRS paid out from FY2015 through FY2024, including $5.3 billion in FY2024 alone · Source: GAO-25-108066
• 7 commissioners — acting or confirmed IRS leaders who have cycled through the agency's top job since early 2025 · Source: Forbes; Senate Finance Committee
• $37.60B — what remains of the IRS's original $79.4 billion Inflation Reduction Act appropriation after subsequent clawbacks — roughly 53% cut · Source: GAO-25-108066; TIGTA

GAO’s letter states its purpose in a single sentence: “The purpose of this letter is to call your personal attention to four areas based on GAO’s past work and 26 open priority recommendations.” Those 26 items break out across five subject areas in the report itself: managing agency transformation, addressing the tax gap, improving the taxpayer experience, ensuring taxpayer data security, and enhancing information reporting. Two of the 26 are brand new to this year’s letter. One, confirmed by title, is “IRS Should Fully Establish Its Approach for Using Evidence to Assess Service Improvement Results” (GAO-25-107408, issued July 17, 2025), filed under the taxpayer-experience area. GAO describes the second new item only as falling within the tax-gap area — this page does not speculate further on its exact title.

To be fair to the agency: this is not a story of total failure. Five recommendations were closed out in the year before this letter, each after sitting open for years — a workforce-planning initiative (six years to close), the modernization of the “Where’s My Refund” tool (two years), a dedicated business identity-theft unit (five years), a systematic evaluation of six key information returns for fraud and compliance risk (four-plus years), and an assessment of how new online services affect taxpayer burden (five-plus years). And as of June 2025, the IRS had implemented 71 percent of GAO’s open recommendations government-wide — essentially in line with the 70 percent baseline rate across all federal agencies. The story here is not that the IRS ignores GAO outright; it is that a specific, high-value subset of fixes keeps getting deferred year after year, some for the better part of a decade.

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The first of GAO’s five areas is managing agency transformation — and it is the one most directly caught up in this year’s restructuring. As GAO’s letter records it: “In March 2025, IRS officials said the office that had been leading the transformation effort had been disbanded.” That office, the Transformation and Strategy Office, had been the IRS’s in-house coordinator for its multi-year modernization push. It was eliminated amid the DOGE-era restructuring that swept federal agencies in the first months of the Trump administration’s second term.

The consequences followed quickly. In April 2025, the IRS paused its quarterly reporting to Congress on IT modernization progress entirely — a requirement GAO had relied on to track whether the agency was fixing the problems it had been told to fix. When GAO pressed on a related recommendation, the agency’s own response was blunt: “IRS stated that it is unknown what organizations or operations will remain as part of the IRS mission after the reduction in force and reorganization… IRS stated that it is impossible to implement this recommendation at this time.” An agency cannot fix what it has stopped tracking, and it cannot commit to a recommendation when it does not yet know which parts of itself will still exist to carry it out.

The second area, addressing the tax gap, is the oldest fight on GAO’s books. “Enforcement of Tax Laws” has sat on GAO’s government-wide High-Risk List since 1990 — 35 years. GAO puts the annual tax gap attributable to sole proprietors alone at $80 billion, a single category of underpayment large enough to fund entire federal agencies. The oldest still-open priority recommendation in this year’s letter — consolidating the IRS’s online referral-submission programs — dates back to 2016, more than nine years open.

Enforcement capacity has moved in the wrong direction at the same time the tax gap sits unresolved. GAO’s letter states plainly: “As of May 2025, IRS workforce reductions have resulted in losing more than 25 percent of its mission-critical tax examiners and revenue officers.” The Treasury Inspector General for Tax Administration put a sharper number on one slice of that loss: Bloomberg reported, citing TIGTA, that the IRS lost 31 percent of its tax auditors amid the DOGE-era downsizing. Fewer examiners chasing an $80 billion annual gap in sole-proprietor compliance is not a formula GAO expects to close it.

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“As of May 2025, IRS workforce reductions have resulted in losing more than 25 percent of its mission-critical tax examiners and revenue officers.”

U.S. Government Accountability Office · GAO-25-108066

The third area, improving the taxpayer experience, has its own price tag. The IRS paid $32.40 billion in refund interest from FY2015 through FY2024, including $5.30 billion in FY2024 alone — money that flows out when the agency is slow to process what it owes taxpayers. A GAO recommendation open since 2019 called for the IRS to analyze the costs and benefits of its Free File program before renewing the underlying agreement with tax-prep companies. The IRS renewed anyway, extending the Free File agreement all the way to October 2029, without producing the cost-benefit analysis GAO had asked for.

The fourth area, ensuring taxpayer data security, has its own six-year holdout: a recommendation on governing third-party access to taxpayer data has been open since 2019, and the IRS says it will not implement it without new statutory authority from Congress. GAO disputes that any new authority is actually required. The fifth area, enhancing information reporting, includes a recommendation on clarifying virtual-currency and FATCA reporting requirements that has been open since 2020 — one GAO itself estimates carries a potential benefit of “a billion or more dollars.” Taken together, the five areas describe an agency that GAO believes is leaving real money and real security exposure on the table, year after year, on recommendations it has already agreed are worth fixing.

GAO’s own letter points to leadership instability as a driver of the stalled recommendations, and the record backs that up. Biden-appointed Commissioner Daniel Werfel departed in January 2025. Billy Long (R), a former Missouri congressman, was confirmed as IRS Commissioner on June 12, 2025 — and removed by President Trump on August 8, 2025, less than two months later. Treasury Secretary Treasury Secretary Scott Bessent (a Trump-administration appointee) then served as Acting IRS Commissioner under the Federal Vacancies Reform Act; his 210-day authority to hold that post expired March 6, 2026, with no permanent, Senate-confirmed nominee installed since. On October 28, 2025, Frank Bisignano (a Trump-administration appointee who also serves as Social Security Commissioner) was installed in a newly created IRS “Chief Executive Officer” role that does not require Senate confirmation.

That arrangement drew a pointed warning in March 2026 from Sen. Ron Wyden (D-OR), Ranking Member of the Senate Finance Committee, joined by Sen. Elizabeth Warren (D-MA) and Sen. Chuck Schumer (D-NY), who said Bessent’s acting authority had lapsed and called the dual-hatted CEO role a workaround for Senate confirmation. Warren put it directly: “There is no reason to see the Trump administration’s appointment of a CEO as anything more than a strategy to avoid the vetting and confirmation process for a replacement commissioner.” The criticism of IRS dysfunction has not come from one side of the aisle alone — in February 2025, House Ways and Means Committee Chairman Rep. Jason Smith (R-MO) separately said “business as usual at the IRS is unacceptable,” a critique aimed at the agency’s performance rather than at the leadership vacancy Democrats flagged a year later. GAO, a nonpartisan legislative-branch agency, is the one institution flagging both problems at once: an agency with 26 stalled priority fixes, run for the past year and a half by a rotating cast of acting officials.

“There is no reason to see the Trump administration's appointment of a CEO as anything more than a strategy to avoid the vetting and confirmation process for a replacement commissioner.”

Sen. Elizabeth Warren (D-MA), with Sens. Wyden (D-OR) and Schumer (D-NY) · March 2026

None of this is a partisan indictment on its face — GAO is nonpartisan, and the IRS’s 71 percent overall recommendation-implementation rate is roughly average for a federal agency. But the 26 items in this specific letter are not routine housekeeping: a disbanded transformation office that stopped Congress’s IT-progress reports, a 35-year-old enforcement gap now missing a quarter of its examiners, a Free File renewal that skipped the cost analysis GAO asked for, a data-security fix stuck since 2019, and an information-reporting gap GAO itself values at a billion dollars or more. Layer on seven changes in IRS leadership in roughly eighteen months — an acting secretary whose authority has since expired, a confirmed commissioner removed within two months, and a new CEO title created to avoid Senate confirmation — and the pattern GAO is describing is an agency whose problems keep getting handed off before anyone in charge has to answer for them.

What to watch next: whether the $37.6 billion remaining from the IRS’s original Inflation Reduction Act appropriation goes toward closing the tax gap GAO has tracked for 35 years, or toward the operational whiplash of another leadership change; and whether a Senate-confirmed commissioner is ever nominated to replace the acting arrangement Wyden, Warren, and Schumer say has already expired. We will update this page as GAO issues its next priority letter and as the leadership question resolves.

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