The American Institute of CPAs (AICPA) has sent an urgent letter to Treasury Secretary and Acting IRS Commissioner Scott Bessent, urging the Internal Revenue Service (IRS) to announce its contingency plan in preparation of a government shutdown on October 1, 2025. In the letter, the AICPA suggested that the IRS reinstate a plan similar to the Fiscal Year 2025 Lapsed Appropriations Contingency Plan released on March 14, 2025, which excepted all IRS employees, and noted that if a similar contingency plan will not be reinstated, the government should retain more essential IRS employees during the extended and upcoming filing season than occurred in prior government shutdowns.
The AICPA expressed concerns over the detrimental impact of a shutdown, saying, “We are concerned that an October government shutdown will impact the timely processing of extended 2024 tax returns due by October 15, 2025, tax-exempt organization returns due November 17, 2025, and expatriate tax returns due December 15, 2025, which has happened previously with prior government shutdowns… Furthermore, a government shutdown may significantly delay the upcoming filing season that would normally start mid-January 2026 and the issuance of critical guidance implementing [the new tax law].”
A shutdown at this time would have a significant impact on taxpayers’ and tax practitioners’ ability to file returns timely, pay taxes, obtain refunds and contact the IRS with questions or issues. The government shutdown during the 2019 filing season caused significant stress on the entire tax system, including:
- Taxpayers continued to receive automated IRS collection notices, notices of intent to levy, and warnings of asset seizures with no means for resolution.
- Guidance implementing the Tax Cuts and Jobs Act likely decelerated without full staffing.
- With audit, examination, and appeals activities suspended, taxpayers were unable to resolve disputes and to stop penalties and interest from accruing.
- Taxpayers and their practitioners experienced unreliable online account access, varying ability to make electronic payments, and an inability to process critical tax documents.
- Taxpayers and their practitioners could not assist identity theft victims or address hardship issues when the IRS phone lines were not operating, and the IRS phone lines experienced significantly heavier call volume and, therefore, longer wait times upon resumption of operations.
“The processing of tax returns and collection of tax revenue is a critical government function that should continue regardless of a government shutdown, and, at a minimum, taxpayers should have recourse to protect their rights and property. The IRS must keep all essential positions working during the shutdown to help make the 2025 extended filing season operate as efficiently as possible and allow for a smooth start to the 2026 filing season,” the AICPA said in the letter.
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