Nina Olson, the National Taxpayer Advocate, has recommended that the IRS review the costs and benefits of delaying refunds payments  until after April 15 in her report to Congress:

The Speedy Issuance of Tax Refunds Drives Refund Fraud and Identity Theft, As More Research Is Needed on the Costs and Benefits of Holding Refunds Until the End of the Filing Season

Most of us in the VITA world are concerned about opportunity of loan products to reemerge created by the February 15 delay. A delay to April 15 would almost guarantee the return of the refund loan and likely create the kind of pay to play system that Nina Olson eloquently argues against.

If refund loans reemerge as a market force, I believe the market will segment itself into two sets of taxpayers a set who pay a premium for tax assistance using a refund advance to receive funds and pay fees with the advance before April 15, and those who use less costly practitioners and online filing services that do not offer a refund advance.  I anticipate that the practitioners offering refund advance will have virtually every customer use it, because the practitioners cannot charge additional fees for the loan.  A practitioner offering the advance must recover the cost of the advance in some other way likely charging higher fees in general.  While the advance drives up cost to the taxpayer, it will not improve the accuracy of preparation that seems to me the definition of a pay to play system.

As the pro bono practitioners, it is probably up to us to make sure the IRS accurately determines the cost to taxpayers of such a change.  If delaying refunds is the best way to protect taxpayer from having their refunds stolen and their children’s identities stolen to make fraudulent claims, the costs may be worth it to the families we serve. Low-income taxpayers are not the priority of the other parties involved, so pay attention to discussions about further delaying refunds make sure other options are assessed.