From these words of prof. Osofsky you understand the importance of an administrative perspective

http://prawfsblawg.blogs.com/prawfsblawg/2015/07/the-future-of-tax-administration.html

The Future of Tax Administration
        In my recent posts, I have been discussing the trend in tax law scholarship toward tax administration, and have suggested possible causes and fruitful areas of inquiry.  In this last post on the subject matter, I want to briefly ask: where might this be going?  My hope is that tax administration scholarship has as significant of a run as recent trends in tax law scholarship.  As a variety of tax scholars have recognized in recent years, how the tax system is administered may be as, if not (in some cases) more, important than what the law is.  And there are so many tax administration programs meriting examination.  To take just a few: the IRS has special programs for taxpayers in the Large Business and International Division (the nation’s largest taxpayers), such as collaborative, pre-filing issue resolution. In a different part of the taxpaying world, the IRS can settle tax debts for less than the amount owed with taxpayers who can’t pay their tax liability and who meet other requirements.  Corporate tax executives hang on the IRS’s every word at  ABA meetings to find out how the IRS intends to apply the law.  And the IRS gives tax advice (not entirely sure to be correct) to individual taxpayers on the phone.  Scholars have suggested in recent years that taxing authorities should play a more prominent role in setting defaults, such as by presumptively taxing or presumptively collecting tax.  How does all this comport with administrative law and scholarship regarding administrative discretion?  I look forward to all my colleagues’ work that will help me find out.

http://www.law.miami.edu/news/2017/april/unpacking-irs-q-tax-law-professor-leigh-osofsky

Unpacking the IRS: Q & A With Tax Law Professor Leigh Osofsky

What are the challenges facing the Internal Revenue Service?
The Internal Revenue Service is severely underfunded, relative to its workload.  The IRS is not only tasked with enforcing the tax law to ensure that all taxpayers pay their fair share of taxes.  It is also tasked with assisting taxpayers in understanding their taxpaying obligations.  As a result of steady budget cuts over the past decade, combined with plans by the current administration to make significant, additional cuts to the IRS budget, the IRS simply does not have the resources to carry out all of its tasks.
What is the future of tax administration?
The IRS has to continue to find ways to innovate in order to do more with less.  This means continuing to develop its technology to make as much of its enforcement automated as possible (through the use of automatic inquiries being sent to taxpayers as a result of errors on the taxpayers’ tax returns).  The IRS is also always continually developing its informational technology to make the best possible use of its resources, for instance by honing audit formulas so that it is targeting the right taxpayers.  On the assistance side, the future is also in automation and technology, to ensure that the IRS is interacting with taxpayers in the most efficient ways possible. This might mean partnering with online tax preparation companies in order for the IRS to be able to interact with taxpayers in real time to get them the assistance (and provide them the compliance reminders they need) at the best possible times.
What changes are needed?
In order to continue to enforce the law, serve taxpayers, innovate, and protect taxpayers' personal information from cyber-attacks, the IRS will need a step-up, not down, in resources.  The IRS is an extremely efficient organization (raising approximately $4 in revenue for every additional dollar in IRS funding).  It serves as the lifeblood of the rest of government, and it will need continued support to do its job.  At the same time, the Taxpayer Advocate’s work on behalf of taxpayers is necessary to ensure that the IRS’s zealous enforcement of the tax law continues to be consistent with public values and public support.