A new report by the Treasury Inspector General for Tax Administration  (TIGTA) states that the IRS has postponed enforcement action in nearly 39,000 high-priority cases involving billions of dollars in potential tax assessments.

Journal of Accountancy reports that, on June 30, 2025, 38,824 cases covering 33,653 taxpayers were still stuck in first-notice status and had not moved on to the agency's usual enforcement procedure. These cases involved potential tax assessments amounting to about $15.7 billion, and TIGTA estimated that taking earlier action could have led to the issuance of returns or assessments totaling an additional $321.3 million in tax.

These cases fell within the scope of the IRS's high-income nonfiler initiative, which was launched in February 2024 with the aim of focusing on taxpayers who had an income of $400,000 or more as well as other priority groups. At first the IRS management asked for the final notices to be postponed since they were concerned about the resources available to deal with the cases, whereas TIGTA later discovered a systemic error that prevented the accounts from progressing.

When TIGTA brought the matter to the IRS's attention, the agency identified the cause and sped up the relevant cases in March 2026. It accepted all of TIGTA's six recommendations.

The report also pointed out more general weaknesses in the IRS's enforcement procedures concerning nonfilers, such as the absence of unified agency-wide supervision and performance reporting. TIGTA stated that nonfilers made up about $63 billion of the IRS's estimated $696 billion total tax gap for the tax year 2022.