Criminal Investigation Had Success With Ghost Employers, While Civil Enforcement Efforts Can Be Improved

The Commissioner, SB/SE Division should confer with the RAAS function on additional research available and incorporate refinements to filters needed to improve the identification of Ghost Employers.

The Director of Collection, SB/SE Division, should use a CIP or similar approach for Ghost Employers, which improves the tracking of enforcement action results and ensures that cases that do not rise to the level of Criminal Investigation involvement are placed into other civil enforcement workstreams.

The Director of Collection, SB/SE Division, should require SB/SE Division leadership to provide a summary of planned actions in response to the Ghost Employer Project team recommendations as noted in this report.

The Director of Collection Policy, SB/SE Division, should issue a reminder to Collection employees to consider referring Ghost Employer cases to Examination for potential civil fraud penalties as outlined in IRM 25.1.6.2(3) when working future Ghost Employer cases.