The IRS has seen its sixth commissioner this year alone. Add in under-resourced staff, outdated systems, and delayed guidance, and tax professionals are staring down an unpredictable season. There is concern that software providers will be left guessing on implementation until the IRS issues instructions, likely well into 2025.

Implications for CPAs:
● Expect delays: returns may not be accepted until mid-February.
● Prepare for mismatches: software updates without IRS guidance are risky.
● Advise clients early about possible filing delays.

When IRS leadership turnover becomes routine, the risk shifts downstream. Practitioners will need to stay
nimble and communicate clearly with clients about uncertainty.

These insights come out of the OB3 Individual and Estate Think Tank discussions, where practitioners are actively sharing how IRS leadership instability could shape the 2025 season.

Learn more about the OB3 and what the COCPA is doing to support our members who are breaking it down and working through it.