Most retirees who filed early in 2024 did so before the IRS had their pension paperwork in hand: the Treasury Inspector General for Tax Administration says the IRS had no Form 1099-R available for 15 million of the 20 million tax returns that reported retirement distributions when those returns were filed in the 2024 season. Together the returns claimed more than $46 billion in refunds. The finding comes from a TIGTA report dated May 13, 2026.

A Form 1099-R is the statement a pension plan, annuity company or IRA custodian files to report what it paid out in a year. The IRS leans on it to check what a retiree puts on a return. When the payer’s copy has not reached the agency yet, no check can happen before the refund goes out.

What TIGTA counted in the 2024 filing season

The numbers sit in TIGTA’s report titled The IRS Continues to Improve the Detection and Prevention of Individual Identity Theft. As of April 15, 2024, about 15 million returns, or 75 percent of the 20 million that reported Form 1099-R income, had no matching information return available when they were filed. TIGTA says those returns claimed over $46 billion in refunds.

Form 1099-R covers distributions from pensions, annuities, retirement and profit-sharing plans, IRAs and insurance contracts. A retiree who files early with any of that income is in the group TIGTA counted. What matters for that retiree is that the amounts typed on the return match the amounts on the payer’s form, because the matching happens after the return is processed.

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The report is about fraud screening, not about delays for honest filers. TIGTA says the IRS “does not always have the information it needs to detect potential fraud patterns before refunds are issued.” The same gap shows up for gambling winnings: about 1 million of the 1.3 million returns reporting Form W-2G income, or 77 percent, had no matching form, tied to $3.6 billion in refunds.

The IRS did catch some of the questionable returns. TIGTA says the agency’s filters flagged about 6,600 returns tied to Forms 1099-R and W-2G in processing year 2024.

Why the forms arrive after the returns

The cause is the calendar. TIGTA says Forms 1099-R and W-2G are due to the IRS on March 31, while Form W-2 and nonemployee compensation returns were moved up to Jan. 31. That leaves a two-month gap between the wage deadline and the retirement deadline.

An earlier TIGTA audit, dated Sept. 30, 2024, made the same point. It said the forms “are generally not available when most tax returns are filed,” so the IRS “must rely on post-processing procedures because some information returns are not due to the IRS until after most tax returns have already been processed.”

That audit looked at tax year 2021 early withdrawals. It found 6.2 million taxpayers with a possibly taxable early distribution, and estimated that 2,297,544 of them may not have fully reported about $11.4 billion as income. TIGTA also noted that the IRS’s Automated Underreporter program identified about 371,000 cases with early distributions that year.

What the IRS says it would do about it

TIGTA’s first recommendation asks the IRS’s Chief of Taxpayer Services to work with the Treasury Office of Tax Policy to request legislation moving up the deadline for every information return now due March 31. The IRS agreed. The report says the agency estimates an earlier deadline could protect $944 million more in revenue over fiscal years 2025 through 2034.

The Journal of Accountancy, reporting on the audit May 21, quoted the IRS as saying an earlier deadline would “significantly enhance” its ability to stop improper claims from being paid. The same story said the IRS stopped about $7 billion in fraudulent refunds across calendar years 2024 and 2025, using filters that selected roughly 7.5 million returns.

Because the fix needs a change in the law, the March 31 date stands until Congress acts. Nothing in the report or in the coverage of it shows a bill that would move the date.

What a mismatch notice looks like

When a payer’s form and a return disagree, the IRS can send a CP2000 notice. The agency’s CP2000 page says the notice means the income or payment information it received from third parties does not match the return. The proposed change could raise the tax, lower it or leave it unchanged, and the page says the notice “isn’t a bill” but a response may be required.

The IRS tells recipients to reply by the date printed on the notice, by upload, fax or mail. Someone who agrees and has nothing else to report follows the notice’s instructions. Someone with other income, credits or expenses to report files Form 1040-X and writes “CP2000” at the top, and anyone who does not reply may get another notice and a bill.

The CP2000 page speaks of 1099s and W-2s in general and does not name Form 1099-R. TIGTA’s 2024 audit is where the link is made: retirement-distribution mismatches are found after processing, which is why a notice can land months after a refund arrives.

None of this changes how a retiree files. It explains why a payer’s form can reach the IRS after a refund has already been paid, and why the match, and any notice, comes later. The one number worth having in hand is the gross distribution on each 1099-R, since that is the figure the IRS will compare.

Does the 1099-R match what the return says?

A pension or IRA withdrawal that is left off or keyed in wrong can come back as a CP2000 notice long after the refund is spent. A retiree then has to sort out which line of income set the tax, and by the date on the notice.

Cut Your Retirement Tax Bill: 12 Moves shows each income line that sets a retiree’s bill, including how much of your Social Security is taxed, worked out on one worksheet. Its 14 pages also put the 2026 numbers on one page, with the form to use for each move.

Get the 1099-R retirement income guide with the 2026 numbers page →

This article was produced with AI assistance and edited for accuracy against the sources linked above.