During the 2024 tax-filing season, the Internal Revenue Service processed 20 million returns reporting pension, annuity, IRA or profit-sharing income from Form 1099-R. For 15 million of those returns — three out of every four — the agency had not yet received the matching information return that the paying bank, insurer or plan administrator is required to send, according to a federal audit. Those 15 million returns had already claimed more than $46 billion in refunds before the IRS had the third-party paperwork needed to check the numbers. The gap traces to a single date on the tax calendar: the March 31 deadline for filing Form 1099-R, which falls roughly two months after the individual filing season opens.
A Broader Audit Turns Up a Narrower Blind Spot
The finding comes from the Treasury Inspector General for Tax Administration’s Report 2026-400-019, issued May 13, 2026 and signed by Diana M. Tengesdal, TIGTA’s Deputy Inspector General for Audit, under the title “The IRS Continues to Improve the Detection and Prevention of Individual Identity Theft.” The audit’s stated objective was broader than retirement income alone — to assess the IRS’s “service-wide revenue protection strategy for individual tax returns” — but one section turned specifically to the information returns the IRS uses to catch fraud before a refund goes out, and to what happens when that information isn’t there yet. As of April 15, 2024, the agency was missing the Form 1099-R data behind 15 million of the 20 million returns that reported pension, annuity, IRA or profit-sharing income that filing season — 75 percent of the total — and those unmatched returns had already claimed over $46 billion in refunds. To confirm the figures, auditors pulled records from the IRS’s Individual Return Transaction File and Information Return Master File and tested samples against the underlying data systems.
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One Form Moved Up, Another Never Did
Earlier legislation accelerated the filing deadline for some information returns — Form W-2 wage statements and nonemployee-compensation reporting among them — to January 31, aligning them with the start of the individual filing season. Form 1099-R never got the same treatment; along with Form W-2G, which reports gambling winnings, it still carries the older March 31 deadline. TIGTA found the identical structural gap on the gambling side of the ledger: 1 million of the 1.3 million returns reporting Form W-2G income — 77 percent — were missing their matching form as of that same April 15, 2024 date, and those returns had claimed $3.6 billion in refunds. For a taxpayer who receives Form 1099-R income — a pension check, an IRA distribution, an annuity payout — that timing means a return can be filed, processed and refunded weeks before the one document that would let the IRS check it against an independent source is even due.
How the Matching Is Supposed to Work, and Why the Timing Breaks It
The IRS’s matching system loads information returns — the copies employers, banks, insurers and plan administrators send directly to the government — into the Information Return Master File, then compares what a taxpayer claims on a Form 1040 against what a third party already reported. TIGTA’s glossary describes that file as being built from weekly extracts starting each January, the same month the individual filing season opens. A Form 1099-R issuer has until March 31 to file its copy, meaning a retiree who files an early return in late January or February is checked against a file that, for that form type, may still be incomplete for another two months. The IRS does still build prerefund identity theft filters around the 1099-R and W-2G data it has on hand, and for Processing Year 2024 those filters flagged about 6,600 questionable returns tied to the two form types combined — a catch that TIGTA’s own numbers show is small next to the 15 million and 1 million returns, respectively, that had no matching form on file as of April 15, 2024.
TIGTA’s Recommendation, and the IRS’s Agreement
TIGTA recommended that the IRS’s Chief, Taxpayer Services, work with the Department of the Treasury’s Office of Tax Policy to request legislation accelerating the filing deadline for every information return still due March 31, Form 1099-R and Form W-2G included. IRS management agreed with the recommendation and said it would share the report with the Office of Tax Policy. The agency’s own estimate attaches a number to the delay: moving up the deadline for those forms could increase the revenue the IRS protects from fraud by $944 million across fiscal years 2025 through 2034, a figure TIGTA’s report attributes to the IRS. No legislation implementing an earlier 1099-R deadline had been enacted as of the report’s publication, which means the 15 million-return gap TIGTA measured in 2024 remains the operating reality for the filing seasons that have followed, including the one now approaching for tax year 2026.
Retirement Withdrawals and the Forms That Report Them
The 1099-R timing gap this piece describes doesn’t change what a retiree still has to plan around every filing season: which account to draw from first, how a pension or IRA withdrawal interacts with Medicare premiums, and which deductions apply once retirement income starts arriving on its own form. None of that planning waits for the IRS’s matching system to catch up.
The Retirement Tax & Withdrawal Planner is a 12-page planner with four calculators — covering provisional income, IRMAA tier, RMD schedule and Roth bracket fill — and the recommended order for withdrawing from different retirement accounts.
See the RMD schedule calculator and the account withdrawal order in The Retirement Tax & Withdrawal Planner.
This article was researched and drafted with the assistance of AI and reviewed by an editor.
Warren Cohen is a finance writer based in Phoenix, Arizona, covering personal finance topics including credit, banking, and beginner investing. He earned his degree in business administration from Arizona State University and began his career working in consumer finance, where he gained direct experience with lending and credit systems. He now writes for personal finance websites and fintech platforms, focusing on clear, practical content that helps readers make informed financial decisions.
