The IRS faces a particularly challenging rollout to the 2019 filing season, best summarized in four words: more work, fewer employees.

President Donald Trump signed the latest tax reform law in December 2017, but the majority of those changes will take effect in the upcoming filing season. However, the IRS still doesn’t have all the guidance it needs to fully implement the law, and continues to face challenging cuts to its workforce and budget.

“Tax reform implementation this year was just a nightmare,” Dennis Ventry Jr., the chairman of the IRS Advisory Council (IRSAC), said in an interview Monday. “Their personnel had to work on reform this year when they otherwise would have been working on something else. So in some respects, it was a lost year when it came to the initiatives that the IRS was currently working on.”

Since 2011, Congress has cut the IRS’s annual budget by more than $2 billion, or about 16 percent, according to IRSAC’s annual report released Nov. 20.

“The draconian cuts to the IRS budget have meant less of everything from personnel to training to taxpayer assistance to enforcement activities to compliance to systems modernization and, ultimately, to tax revenue,” IRSAC wrote in its report.

As a result, the IRS employs about 24,000 fewer full-time employees than it did in 2010. About 17,000 of those job cuts come from the agency’s tax enforcement. As a result, IRSAC projects the agency failed to collect $58-to-84 billion over the last eight years due to workforce cuts.

“Those who are still there are doing their job, and then some part of somebody else’s job who was fired or who was let go,” Ventry said.

Congress did allocate extra funding for tax reform in FY 2018 — about $320 million — but Ventry said that amounted to a “drop in the bucket of what was needed.”

Meanwhile, he said, IRS employees continue to receive guidance on implementing the tax reform law, for a filing season that will begin in January.

“Guidance is still trickling out, and I’m not even sure they’re going to have all the guidance out by the end of the year,” he said.

The IRSAC isn’t the only IRS partner that’s expressed concerns about the 2019 filing season.

The Treasury Inspector General on Tax Administration (TIGTA) raised concerns in September that the 2019 filing season could face delays, citing the workload and missed IT deadlines.

The watchdog office estimated that it would take more than a million work hours to update about 450 forms and 140 IT systems in time for the 2019 filing season. The IRS told TIGTA it had 542 full-time employees working to implement the law, and put another 117 new and current employees onto the project since June 2018.

Tony Reardon, president of the National Treasury Employees Union, said in a Nov. 20 statement that the union agrees with IRSAC’s conclusions about the state of IRS’s budget.

“The opening of the new tax filing season is around the corner and front-line IRS employees are worried that they will not be fully trained on the massive changes to the new tax code,” Reardon said. “Taxpayers and business owners are going to demand quick and accurate answers to their questions, and the agency needs 2019 appropriations to help hire, train and equip them to be ready.”

IRS Commissioner Charles Retting, a former IRSAC chairman, has taken the council’s concerns to heart.

Last month, Rettig dropped by one of IRSAC’s work sessions and spoke with members about their concerns.

“Commissioner Rettig is a big personality, and with that is a real love and respect for the IRS as an agency, and I have no doubt that he is going to be a very powerful advocate for the agency and for its employees,” Ventry said.

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