Now that the Supreme Court has issued its ruling on the Affordable Care Act, many are taking a closer look at how the law will be implemented, including at the new enforcement duties given to the IRS. The Government Accountability Office has said the IRS faces "a massive undertaking." The National Taxpayer Advocate believes that "with proper planning and funding, the IRS is fully capable of implementing healthcare reform." I am not so sure. And even if the IRS comes through on healthcare, will tax administration be damaged in the process? I know the service will do its level best to implement healthcare reform, but the IRS confronts a long list of challenges. Several concerns are particularly important.