AT Think

Will the 2026 tax season be seamless or doomsday?

We are all bracing for impact. If you work in tax, you have spent the last several months looking at the numbers and shaking your head. The government shut down for a record 43 days. The IRS lost nearly a quarter of its staff throughout 2025. By any normal metric, the 2026 filing season should be a logistical nightmare. We expect long hold times, unprocessed mail piling up in trailers, and a general sense of chaos.

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But former IRS Commissioners Charles Rettig and Danny Werfel disagree, sharing an optimistic view of the agency's ability to pull off a successful tax filing season.

I listened to former Commissioner Rettig speak at the ABA Section of Taxation conference in Las Vegas on Dec. 12, and I chatted with him at length. He didn't just say we would survive. He said, "I think filing season '26 is going to be seamless, and I'm relying on the people of the IRS to make it happen."

That is a bold claim. When you look at the attrition rates and the budget cuts, "seamless" is not the word that comes to mind. But Rettig isn't speaking from a place of naive optimism. He ran the agency during the 35-day shutdown in 2019. He steered it through the absolute upheaval of the COVID-19 pandemic.

His point is simple: The IRS has a culture of survival. There will be bumps. There are always bumps, even when the budget is flush and the staff is full. But the remaining employees, the ones who stayed through the cuts, are going to grind it out. They will work the extra hours. They will clear the queues.

This leaves us with a strange disconnect. The data says disaster. Leadership that we know and trust says resilience. As tax professionals, we need to figure out which version of reality is going to show up on tax season opening day.

The tech gamble and the new "digital mandate"

The only way Rettig's prediction holds water is if the technology actually works. This is where former Commissioner Danny Werfel comes in. For the last two years, Werfel has been betting the house on modernization. In his landmark speech at American University, he called it a "generational imperative," arguing that if banks can offer seamless, mobile, always-on service, the IRS has no excuse for operating like it is 1985.

We have to talk about Direct File. Werfel was its biggest champion. He viewed it as a cornerstone of a modern, accessible tax system. But that program is dead for this season. It is not happening. While Werfel supported it heavily, the resources and political will shifted, and it is off the table for 2026.

But while Direct File is out, a much more aggressive change is in. In a move that will fundamentally alter how we manage cash flow of many of our clients, the Treasury and the IRS have eliminated most paper check refunds. If your client wants their refund, they must provide direct deposit information or be prepared to receive it in other digital formats. Of course, there are exceptions, but they are limited.

It will get stricter. We can expect the Treasury to require that most payments be made digitally in the not too distant future, possibly sometime during the 2026 tax season. The days of stapling a paper check to a 1040-V voucher and dropping it in the mail will be over. The IRS is moving to eliminate paper processing and the associated costs, delays and lost mail. 

This mandate changes the game for the season. Werfel promised "paperless processing" by the 2025 filing season, and this new rule will help move that forward. If the IRS can successfully digitize correspondence and force all money movement into electronic channels, we might actually avoid the mailroom backlogs that haunted us in 2021 and 2022.

In Las Vegas, Werfel reiterated his vision of an IRS where you never have to call or lick a stamp. You handle the notice online. You check the refund status on a phone. You pay your balance via bank transfer. If this works, it frees up the depleted staff to handle the things computers can't fix. However, if it fails, or if the payment portals crash under the load, that 25% staffing cut is going to feel like 50%.

The human element

You cannot automate everything. This is where Rettig's philosophy acts as a necessary counterweight to Werfel's tech focus. Rettig has always been laser-focused with the people the system leaves behind. He speaks and writes often about underserved communities, taxpayers who don't speak English, and the people who can't just "log in" to solve a problem.

A new ban on paper checks and payments puts Rettig's concerns front and center. What happens to the unbanked? What happens to the elderly client who refuses to use online banking?

During his tenure, Rettig pushed hard for multilingual access and expanded partnerships with 15,000 community organizations. He launched the "Lifting Communities Up" initiative to hire people in the Mississippi Delta and Puerto Rico. This matters for 2026 because the staff cuts are likely to hit these areas hard. When you lose a quarter of your workforce, the first things to go are often the high-touch, time-intensive services. Rettig is relying on the idea that the remaining staff understand the mission. He believes they will protect the vulnerable taxpayers because that is what they do.

For us, this means we need to watch our clients in these demographics closely. If the local Taxpayer Assistance Center is closed because there is no one to staff the desk, and they can't cut a check to pay their bill, those clients are going to come to us for help. We are going to be the bridge.

What this means for your practice

So, we have a tech-heavy strategy from Werfel and a "grit and resilience" strategy from Rettig. Here is how you need to adjust your workflow for the coming months:

1. Banking is now part of tax prep. With the elimination of paper checks and the mandate for digital payments, you need to verify client banking details with the same rigor as you verify their Social Security numbers. The best practice for filing a return with a "balance due" is electronic payment. For some clients, you will have to facilitate the payment electronically at the time of filing or guide them to the IRS payment portal. If a client doesn't have a bank account, you need to solve that problem before you file.

2. Digital is not optional anymore. If you are still paper-filing anything that can be e-filed, you are doing a disservice to your client. With the staffing cuts, paper is going to sit. It might sit for months. The paperless processing initiative means the digital pipe is wide open, but the analog pipe is clogged. Scan everything. Upload everything. If a form allows a digital signature, use it.

3. Prepare for "automated compliance." With fewer humans to run audits, the IRS is going to lean on data. Werfel has been clear about this. They are using AI and analytics to spot discrepancies. This means more automated notices (such as CP2000s) and fewer field audits for mid-level issues. Tell your clients now: if the numbers on the return don't match the 1099s exactly, they will get a letter. The computer doesn't get tired, and it doesn't get laid off.

4. The "high-wealth" pivot. IRS officials have been saying for years they want to go after high-income non-filers and complex partnerships. Even with the cuts, they will protect the teams working on these cases. If you represent high-net-worth individuals, do not expect a free pass just because the agency is shrinking. They will move resources from customer service to enforcement in this sector. The audit might be slower, but it will be just as thorough.

5. Manage expectations on phone support. Rettig says the staff will step up. I believe him. But there are physical limits to what 75% of a workforce can do. Hold times will be long. The Practitioner Priority Service might not feel very "priority." You need to set this expectation with clients now. Tell them that resolving a notice might take six months. If you promise a quick fix, you are setting yourself up to fail.

The verdict

I don't think 2026 will be a disaster. The IRS has survived worse. The 2019 shutdown was brutal, and they still processed the returns. The pandemic was a global catastrophe, and they still sent out the stimulus checks. Rettig is right about the culture. The employees who are left are the veterans. They know how to move the paper.

But "seamless" is a strong word. I think we are looking at a bifurcated season.

If your client fits in the digital box, for example, W-2s, standard deductions, e-filed return, direct deposit, digital payment ... it will be seamless. The agency's tech upgrades will work. The refund will show up in 21 days.

If your client falls outside that box (e.g., identity theft issues, amended returns, complex correspondence, or an inability to pay digitally), it is going to be a grind. The lack of bodies will show up in the exceptions.

Our job this year is to keep our clients in the "seamless" lane as much as possible. Clean data. Electronic filing. Digital payments. The IRS is trying to modernize its way out of a staffing crisis. It's a high-wire act. Rettig thinks they will make it across. Werfel built the safety net. Now we just have to wait and see if it holds.

A final thought on resilience

There's a reason why Rettig focused on the employees in Las Vegas. It's easy to look at the IRS as a monolith, a faceless bureaucracy that sends bills. But it is made up of people who have had a terrible year. They faced a shutdown where they didn't get paid. They watched their colleagues leave. They are being asked to do more work with less help.

When you do get an agent on the phone this season, remember that. They are the ones keeping the system running. They are the reason the whole thing doesn't collapse. We can complain about the policy, the funding and the tech, but we should respect the person on the other end of the line. They are the primary reason Rettig's prediction has a chance of coming true..

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