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Testimony: 

Before the Committee on the Budget, House of Representatives: 

United States Government Accountability Office: 

GAO: 

For Release on Delivery Expected at 10:00 a.m. EST: 

Friday, February 16, 2007: 

Tax Compliance: 

Multiple Approaches Are Needed to Reduce the Tax Gap: 

Statement of Michael Brostek: 
Director, Tax Issues Strategic Issues: 

GAO-07-488T: 

GAO Highlights: 

Highlights of GAO-07-488T, a testimony to the Committee on the Budget, 
House of Representatives 

Why GAO Did This Study: 

The tax gap—the difference between the tax amounts taxpayers pay 
voluntarily and on time and what they should pay under the law—has been 
a long-standing problem in spite of many efforts to reduce it. Most 
recently, the Internal Revenue Service (IRS) estimated a gross tax gap 
for tax year 2001 of $345 billion and estimated it would recover $55 
billion of this gap, resulting in a net tax gap of $290 billion. When 
some taxpayers fail to comply, the burden of funding the nation’s 
commitments falls more heavily on compliant taxpayers. Reducing the tax 
gap would help improve the nation’s fiscal stability. For example, each 
1 percent reduction in the net tax gap would likely yield $3 billion 
annually. 

GAO was asked to discuss the tax gap, various approaches to reduce it, 
and what the proposed budget for fiscal year 2008 says about it. This 
testimony discusses the need for taking multiple approaches and to what 
extent the tax gap could be reduced through three overall 
approaches—simplifying or reforming the tax system, providing IRS with 
additional enforcement tools, and devoting additional resources to 
enforcement. This statement is based on prior GAO work. 

What GAO Found: 

Multiple approaches are needed to reduce the tax gap. No single 
approach is likely to fully and cost-effectively address noncompliance 
since, for example, it has multiple causes and spans different types of 
taxes and taxpayers. Simplifying or reforming the tax code, providing 
IRS more enforcement tools, and devoting additional resources to 
enforcement are three major approaches. Moreover, providing quality 
services to taxpayers is a necessary foundation for voluntary 
compliance. Such steps as periodically measuring noncompliance and its 
causes, setting tax gap reduction goals, optimizing the allocation of 
IRS’s resources, and leveraging technology to enhance IRS’s efficiency 
would also contribute to tax gap reduction. 

Simplifying the tax code or fundamental tax reform has the potential to 
reduce the tax gap by billions of dollars. IRS has estimated that 
errors in claiming tax credits and deductions for tax year 2001 
contributed $32 billion to the tax gap. Thus, considerable potential 
exists. However, these provisions serve purposes Congress has judged to 
be important and eliminating or consolidating them could be 
complicated. Fundamental tax reform would most likely result in a 
smaller tax gap if the new system has few, if any, exceptions (e.g., 
few tax preferences) and taxable transactions are transparent to tax 
administrators. These characteristics are difficult to achieve, and any 
tax system could be subject to noncompliance. 

Withholding and information reporting are particularly powerful tools 
to reduce the tax gap. They could help reduce the tax gap by billions 
of dollars, especially if they make underreported income transparent to 
IRS. These tools have led to high, sustained levels of taxpayer 
compliance and improved IRS resource allocation by helping IRS identify 
and prioritize its contacts with noncompliant taxpayers. As GAO 
previously suggested, reporting the cost, or basis, of securities sales 
is one option to improve taxpayers’ compliance. However, designing 
additional withholding and information reporting requirements may be 
challenging given that many types of income are already subject to 
reporting, underreporting exists in many forms, and withholding and 
reporting requirements impose costs on third parties. 

Devoting additional resources to enforcement has the potential to help 
reduce the tax gap by billions of dollars. However, determining the 
appropriate level of IRS enforcement resources requires considering 
such factors as how well IRS uses its resources and the proper balance 
between taxpayer service and enforcement activities. If Congress 
provides IRS more enforcement resources, the amount of tax gap 
reduction would depend on factors such as the size of budget increases 
and the indirect increase in taxpayers’ voluntary compliance resulting 
from expanded enforcement. The recent budget request for fiscal year 
2008 proposes legislation and new initiatives to reduce the tax gap but 
expected dollar gains are modest. Further reductions likely would 
require many more such changes. 

What GAO Recommends: 

GAO is not making any new recommendations but highlights areas for 
possible attention. 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-488T]. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Michael Brostek at (202) 
512-9110 or brostekm@gao.gov. 

[End of section] 

Chairman Spratt, Mr. Ryan, Members of the Committee: 

I appreciate this opportunity to discuss the tax gap--the difference 
between what taxpayers pay in taxes voluntarily and on time and what 
they should pay under the law--and what is achievable in reducing the 
gap. Most recently, the Internal Revenue Service (IRS) estimated that 
for tax year 2001, taxpayers paid about 84 percent of the taxes that 
should have been paid on time under the law, resulting in an estimated 
gross tax gap of $345 billion. IRS estimated that it would eventually 
recover around $55 billion of the 2001 tax gap through late payments 
and IRS enforcement actions, leaving a net tax gap of $290 
billion.[Footnote 1] Because of taxpayer noncompliance, the burden of 
funding the nation's commitments falls more heavily on taxpayers who 
willingly and accurately pay their taxes. Reducing the tax gap would 
help improve the nation's fiscal stability. For example, based on IRS's 
estimate, each 1 percent reduction in the net tax gap would likely 
yield nearly $3 billion annually. However, the tax gap has been a 
persistent problem in spite of a myriad of congressional and IRS 
efforts to reduce it, as the rate at which taxpayers voluntarily comply 
with our tax laws has changed little over the past three decades. 
Likewise, factors such as globalization and the ever-increasing 
complexity of the tax code challenge IRS's ability to administer the 
tax code. 

My remarks focus on what is achievable in reducing the tax gap through 
a variety of approaches. First I will discuss the need for multiple 
approaches toward reducing the tax gap. Then I will discuss three 
specific tax gap reduction approaches: (1) simplifying or reforming the 
tax system; (2) providing IRS additional enforcement authority and 
tools, such as information reporting[Footnote 2] and tax 
withholding,[Footnote 3] through changes to the tax laws; and (3) 
devoting additional resources to enforcement under the existing tax 
laws. My remarks are based on our previous work on a variety of issues, 
in particular, recent testimonies and a report on reducing the tax 
gap.[Footnote 4] These efforts were conducted in accordance with 
generally accepted government auditing standards. 

Let me begin by highlighting four major points: 

* Multiple approaches are needed to reduce the tax gap. No single 
approach is likely to fully and cost-effectively address noncompliance 
since, for example, it has multiple causes and spans different types of 
taxes and taxpayers. Simplifying or reforming the tax code, providing 
IRS more enforcement tools, and devoting additional resources to 
enforcement are three major approaches discussed below, but providing 
quality services to taxpayers also is a necessary foundation for 
voluntary compliance. Quality services can help taxpayers who wish to 
comply but do not understand their obligations, whereas enforcement 
actions may be needed for those who intentionally evade their tax 
obligations. Such steps as periodically measuring noncompliance and its 
causes, setting tax gap reduction goals, considering the costs and 
benefits of initiatives to reduce the gap, evaluating the results of 
such initiatives undertaken, optimizing the allocation of IRS's 
resources, and leveraging technology to enhance IRS's efficiency would 
also contribute to tax gap reduction. 

* Simplifying the tax code or fundamental tax reform has the potential 
to reduce the tax gap by many billions of dollars. For example, IRS 
estimated that errors in claiming tax credits and deductions for tax 
year 2001 contributed $32 billion to the tax gap. Reducing the number 
of such credits and deductions therefore has some direct potential to 
reduce the tax gap. However, these credits and deductions serve 
purposes Congress has judged to be important, and eliminating them 
likely would be complicated. Fundamental tax reform, such as shifting 
to a consumption tax system, would most likely result in a smaller tax 
gap if the new system has few, if any, exceptions (e.g., few or no tax 
preferences) and taxable transactions are transparent to tax 
administrators. These characteristics are difficult to achieve in any 
system, and any tax system could be subject to noncompliance. 

* Providing IRS with more enforcement tools, particularly withholding 
and information reporting, also has the potential to reduce the tax gap 
by billions of dollars, especially if those tools help IRS deal with 
the largest contributor to the tax gap--underreported income. Tax 
withholding and information reporting have been shown to lead to high, 
sustained levels of taxpayer compliance because the income taxpayers 
earn is transparent to them and IRS. Also, using these tools can help 
IRS better allocate its resources by improving its ability to identify 
and prioritize noncompliant taxpayers to be contacted. For example, we 
found that having third parties report to taxpayers and IRS the cost, 
or basis, of stocks and mutual funds that taxpayers sell could help 
taxpayers improve their voluntary compliance and help IRS allocate its 
enforcement efforts concerning these transactions. However, designing 
withholding or information reporting requirements to address 
underreporting may be challenging given that many types of income are 
already subject to such requirements, underreporting exists in many 
forms, and any requirements could impose costs and burdens on the third 
parties that withhold or report. 

* Devoting additional resources to enforcement has the potential to 
help reduce the tax gap by billions of dollars. However, determining 
the appropriate level of enforcement resources to provide IRS requires 
taking into account factors such as how effectively and efficiently IRS 
is currently using its resources, how to strike the proper balance 
between IRS's taxpayer service and enforcement activities, and 
competing federal funding priorities. If Congress were to provide IRS 
more enforcement resources, the amount the tax gap could be reduced 
depends in part on factors such as the size of budget increases, how 
IRS manages any additional resources, and the indirect increase in 
taxpayers' voluntary compliance resulting from expanded enforcement. 
Providing IRS with additional funding would enable it to contact 
millions of potentially noncompliant taxpayers it identifies but 
currently cannot contact given resource constraints. 

The administration's budget request for fiscal year 2008 recognizes the 
need for multiple approaches to tax gap reduction. It offers 16 
legislative proposals and hundreds of millions of dollars for new IRS 
initiatives to reduce the tax gap. Among other things, these proposals 
address taxpayer services as well as two other approaches--expanded 
information reporting and additional enforcement resources for IRS. 
Even with these efforts, however, the dollar amounts expected to be 
raised are quite small compared to the size of the tax gap. This 
underscores the likelihood that more significant reductions in the tax 
gap will require many additional actions under a multiple approaches 
strategy given the variety of taxes, taxpayers, and types of 
noncompliance that contribute to the tax gap. 

Background: 

The tax gap is an estimate of the difference between the taxes-- 
including individual income, corporate income, employment, estate, and 
excise taxes--that should have been paid voluntarily and on time and 
what was actually paid for a specific year. The estimate is an 
aggregate of estimates for the three primary types of noncompliance: 
(1) underreporting of tax liabilities on tax returns; (2) underpayment 
of taxes due from filed returns; and (3) nonfiling, which refers to the 
failure to file a required tax return altogether or on time.[Footnote 
5] IRS's tax gap estimates for each type of noncompliance include 
estimates for some or all of the five types of taxes that IRS 
administers. As shown in table 1, underreporting of tax liabilities 
accounted for most of the tax gap estimate for tax year 2001. 

Table 1: IRS's Tax Year 2001 Gross Tax Gap Estimates by Type of 
Noncompliance and Type of Tax: 

Dollars in billions. 

Type of noncompliance: Underreporting; 
Type of tax: Individual income tax: $197; 
Type of tax: Corporate income tax: $30; 
Type of tax: Employment tax: $54; 
Type of tax: Estate tax: $4; 
Type of tax: Excise tax: No estimate; 
Total: $285. 

Type of noncompliance: Underpayment; 
Type of tax: Individual income tax: 23; 
Type of tax: Corporate income tax: 2; 
Type of tax: Employment tax: 5; 
Type of tax: Estate tax: 2; 
Type of tax: Excise tax: $1; 
Total: $34. 

Type of noncompliance: Nonfiling; 
Type of tax: Individual income tax: 25; 
Type of tax: Corporate income tax: No estimate; 
Type of tax: Employment tax: No estimate; 
Type of tax: Estate tax: 2; 
Type of tax: Excise tax: No estimate; 
Total: $27. 

Type of noncompliance: Total; 
Type of tax: Individual income tax: $244; 
Type of tax: Corporate income tax: $32; 
Type of tax: Employment tax: $59; 
Type of tax: Estate tax: $8; 
Type of tax: Excise tax: $1; 
Total: $345. 

Source: IRS. 

Note: Figures may not sum to totals because of rounding. 

[End of table] 

IRS has estimated the tax gap on multiple occasions, beginning in 1979, 
relying on its Taxpayer Compliance Measurement Program (TCMP). IRS did 
not implement any TCMP studies after 1988 because of concerns about 
costs and burdens on taxpayers. Recognizing the need for current 
compliance data, in 2002 IRS implemented a new compliance study called 
the National Research Program (NRP) to produce such data for tax year 
2001 while minimizing taxpayer burden. 

IRS has concerns with the certainty of the tax gap estimate for tax 
year 2001 in part because some areas of the estimate rely on old data, 
IRS has no estimates for other areas of the tax gap, and it is 
inherently difficult to measure some types of noncompliance. IRS used 
data from NRP to estimate individual income tax underreporting and the 
portion of employment tax underreporting attributed to self-employed 
individuals. The underpayment segment of the tax gap is not an 
estimate, but rather represents the tax amounts that taxpayers reported 
on time but did not pay on time. Other areas of the estimate, such as 
corporate income tax and employer-withheld employment tax 
underreporting, rely on decades-old data. Also, IRS has no estimates 
for corporate income, employment, and excise tax nonfiling or for 
excise tax underreporting.[Footnote 6] In addition, it is inherently 
difficult for IRS to observe and measure some types of underreporting 
or nonfiling, such as tracking cash payments that businesses make to 
their employees, as businesses and employees may not report these 
payments to IRS in order to avoid paying employment and income taxes, 
respectively.[Footnote 7] 

IRS's overall approach to reducing the tax gap consists of improving 
service to taxpayers and enhancing enforcement of the tax laws. IRS 
seeks to improve voluntary compliance through efforts such as education 
and outreach programs and tax form simplification. IRS uses its 
enforcement authority to ensure that taxpayers are reporting and paying 
the proper amounts of taxes through efforts such as examining tax 
returns and matching the amount of income taxpayers report on their tax 
returns to the income amounts reported on information returns it 
receives from third parties. IRS reports that it collected over $48 
billion in fiscal year 2006 from noncompliant taxpayers it identified 
through its various enforcement programs. 

In spite of IRS's efforts to improve taxpayer compliance, the rate at 
which taxpayers pay their taxes voluntarily and on time has tended to 
range from around 81 percent to around 84 percent over the past three 
decades. Any significant reduction of the tax gap would likely depend 
on an improvement in the level of taxpayer compliance.[Footnote 8] 

Congress has been encouraging IRS to develop an overall tax gap 
reduction plan or strategy that could include a mix of approaches like 
simplifying code provisions, increased enforcement, and reconsidering 
the level of resources devoted to enforcement. Some progress has been 
made toward laying out the broad elements of a plan or strategy for 
reducing the tax gap. On September 26, 2006, the U.S. Department of the 
Treasury (Treasury), Office of Tax Policy, released "A Comprehensive 
Strategy for Reducing the Tax Gap." However, the document generally 
does not identify specific steps that Treasury and IRS will undertake 
to reduce the tax gap, the related time frames for such steps, or 
explanations of how much the tax gap would be reduced. Furthermore, the 
document mentioned the importance of establishing benchmarks against 
which progress on each step under the strategy could be measured. It 
said that after the fiscal year 2008 budget request was released, 
Treasury and IRS would issue more details in March or April 2007 about 
the steps they would take to reduce opportunities for evasion and 
address the tax gap. 

The 2008 budget request issued on February 5, 2007, suggested 16 
legislative changes to expand or improve information reporting, improve 
compliance by businesses, strengthen tax administration, and expand 
penalties. It also proposed additional funding for new initiatives 
aimed at reducing the tax gap. 

Multiple Approaches Are Needed to Reduce the Tax Gap: 

No single approach is likely to fully and cost-effectively address 
noncompliance and therefore multiple approaches are likely to be 
needed. The tax gap has multiple causes; spans five types of taxes; and 
is spread over several types of taxpayers including individuals, 
corporations, and partnerships. Thus, for example, while simplifying 
laws should help when noncompliance is due to taxpayers' confusion, 
enforcement may be needed for taxpayers who understand their 
obligations but decline to fulfill them. Similarly, while devoting more 
resources to enforcement should increase taxes assessed and collected, 
too great an enforcement presence likely would not be tolerated. 

Simplifying or reforming the tax code, providing IRS more enforcement 
tools, and devoting additional resources to enforcement are three major 
tax gap reduction approaches discussed in more detail below, but 
providing quality services to taxpayers plays an important role in 
improving compliance and reducing the tax gap. IRS taxpayer services 
include education and outreach programs, simplifying the tax process, 
and revising forms and publications to make them electronically 
accessible and more easily understood by diverse taxpayer communities. 
For example, if tax forms and instructions are unclear, taxpayers may 
be confused and make unintentional errors. Quality taxpayer services 
would also be a key consideration in implementing any of the approaches 
for tax gap reduction. For example, expanding enforcement efforts would 
increase interactions with taxpayers, requiring processes to 
efficiently communicate with taxpayers. Also, changing tax laws and 
regulations would require educating taxpayers about the new 
requirements in a clear, timely, and accessible manner. In 2006, we 
reported that IRS improved its two most commonly used services-- 
telephone and Web site assistance--for the 2006 filing season.[Footnote 
9] Increased funding financed some of the improvements, but a 
significant portion has been financed internally by efficiencies gained 
from increased electronic filing of tax returns and other operational 
improvements. 

Although quality service helps taxpayers comply, showing a direct 
relationship between quality service and compliance levels is very 
challenging. As required by Congress, IRS is in the midst of a study 
that is to result in a 5-year plan for taxpayer service activities, 
which is to include long-term quantitative goals and to balance service 
and enforcement. Part of the study focuses on the effect of taxpayer 
service on compliance. A Phase I report was issued in April 2006 and a 
Phase II report should be completed in fiscal year 2007, which is to 
include, among other things, a multiyear plan for taxpayer service 
activities and improvement initiatives. 

However, in deciding on the appropriate mix of approaches to use in 
reducing the tax gap, many factors or issues could affect strategic 
decisions. Among the broad factors to consider are the likely 
effectiveness of any approach, fairness, enforceability, and 
sustainability. Beyond these, our work points to the importance of the 
following: 

* Measuring compliance levels periodically and setting long-term goals. 
A data-based plan is one key to closing the tax gap. To the extent that 
IRS can develop better compliance data, it can develop more effective 
approaches for reducing the gap. Regularly measuring the magnitude of, 
and the reasons for, noncompliance provides insights on how to reduce 
the gap through potential changes to tax laws and IRS programs. In July 
2005, we recommended that IRS periodically measure tax compliance, 
identify reasons for noncompliance, and establish voluntary compliance 
goals.[Footnote 10] IRS agreed with the recommendations and established 
a voluntary tax compliance goal of 85 percent by 2009. Furthermore, we 
have identified alternative ways to measure compliance, including 
conducting examinations of small samples of tax returns over multiple 
years, instead of conducting examinations for a larger sample of 
returns for 1 tax year, to allow IRS to track compliance trends 
annually. The administration's fiscal year 2008 budget proposal offers 
this idea by requesting funds to annually study compliance based on a 
smaller sample size than the 2001 NRP study. 

* Considering the costs and burdens. Any action to reduce the tax gap 
will create costs and burdens for IRS; taxpayers; and third parties, 
such as those who file information returns. For example, withholding 
and information reporting requirements impose some costs and burdens on 
those who track and report information. These costs and burdens need to 
be reasonable in relation to the improvements expected to arise from 
new compliance strategies. 

* Evaluating the results. Evaluating the actions taken by IRS to reduce 
the tax gap would help maximize IRS's effectiveness. Evaluations can be 
challenging because it is difficult to isolate the effects of IRS's 
actions from other influences on taxpayers' compliance. Our work has 
discussed how to address these challenges, for example by using 
research to link actions with the outputs and desired effects. 

* Optimizing resource allocation. Developing reliable measures of the 
return on investment for strategies to reduce the tax gap would help 
inform IRS resource allocation decisions. IRS has rough measures of 
return on investment based on the additional taxes it assesses. 
Developing such measures is difficult because of incomplete data on the 
costs of enforcement and collected revenues. Beyond direct revenues, 
IRS's enforcement actions have indirect revenue effects, which are 
difficult to measure. However, indirect effects could far exceed direct 
revenue effects and would be important to consider in connection with 
continued development of return on investment measures. In general 
though, the effects of tax gap reduction by improving voluntary tax 
compliance can be quite large. For example, if the estimated 83.7 
percent voluntary compliance rate that produced a gross tax gap of $345 
billion in tax year 2001 had been 85 percent, this tax gap would have 
been about $28 billion less; if it had been 90 percent, the gap would 
have been about $133 billion less. 

* Leveraging technology. Better use of technology could help IRS be 
more efficient in reducing the tax gap. IRS is modernizing its 
technology, which has paid off in terms of telephone service, resource 
allocation, electronic filing, and data analysis capability. However, 
this ongoing modernization will need strong management and prudent 
investments to maximize potential efficiencies. The administration's 
fiscal year 2008 budget proposal requests additional funds under its 
Business Systems Modernization initiatives. 

Reducing the Tax Gap through Tax Simplification or Tax System Reform 
Depends on Their Design and May Have Effects Beyond Tax Compliance: 

Tax law simplification and reform both have the potential to reduce the 
tax gap by billions of dollars. The extent to which the tax gap would 
be reduced depends on which parts of the tax system would be simplified 
and in what manner, as well as how any reform of the tax system is 
designed and implemented. Neither approach, however, will eliminate the 
gap. Further, changes in the tax laws and system to improve tax 
compliance could have unintended effects on other tax system 
objectives, such as those involving economic behavior or equity. 

Simplification has the potential to reduce the tax gap for at least 
three broad reasons. First, it could help taxpayers to comply 
voluntarily with more certainty, reducing inadvertent errors by those 
who want to comply but are confused because of complexity. Second, it 
may limit opportunities for tax evasion, reducing intentional 
noncompliance by taxpayers who can misuse the complex code provisions 
to hide their noncompliance or to achieve ends through tax shelters. 
Third, tax code complexity may erode taxpayers' willingness to comply 
voluntarily if they cannot understand its provisions or they see others 
taking advantage of complexity to intentionally underreport their 
taxes. 

Simplification could take multiple forms. One form would be to retain 
existing laws but make them simpler. For example, in our July 2005 
report[Footnote 11] on postsecondary tax preferences, we noted that the 
definition of a qualifying postsecondary education expense differed 
somewhat among some tax code provisions, for instance with some 
including the cost to purchase books and others not. Making definitions 
consistent across code provisions may reduce taxpayer errors. Although 
we cannot say the errors were due to these differences in definitions, 
in a limited study of paid preparer services to taxpayers, we found 
some preparers claiming unallowable expenses for books.[Footnote 12] 
Further, the Joint Committee on Taxation suggested that such dissimilar 
definitions may increase the likelihood of taxpayer errors and increase 
taxpayer frustration.[Footnote 13] 

Another tax code provision in which complexity may have contributed to 
the individual tax gap involves the earned income tax credit, for which 
IRS estimated a tax loss of up to about $10 billion for tax year 
1999.[Footnote 14] Although some of this noncompliance may be 
intentional, we[Footnote 15] and the National Taxpayer 
Advocate[Footnote 16] have previously reported that confusion over the 
complex rules governing eligibility for claiming the credit could cause 
taxpayers to fail to comply inadvertently. The administration's fiscal 
year 2008 budget proposes legislative language to simplify eligibility 
requirements for the credit as well as to clarify the uniform 
definition of a qualifying child. 

Another form of simplification could be to broaden the tax base while 
reducing tax rates, which could minimize incentives for not complying. 
This base-broadening could include a review of whether existing tax 
expenditures are achieving intended results at a reasonable cost in 
lost revenue and added burden and eliminating or consolidating those 
that are not. Among the many causes of tax code complexity is the 
growing number of preferential provisions in the code, defined in 
statute[Footnote 17] as tax expenditures, such as tax exemptions, 
exclusions, deductions, credits, and deferrals.[Footnote 18] The number 
of these tax expenditures has more than doubled from 67 in 1974 to 161 
in 2006, and the sum of tax expenditure estimates rose to nearly $847 
billion.[Footnote 19] Tax expenditures can contribute to the tax gap if 
taxpayers claim them improperly. For example, IRS's recent tax gap 
estimate includes a $32 billion loss in individual income taxes for tax 
year 2001 because of noncompliance with these provisions. Simplifying 
these provisions of the tax code would not likely yield $32 billion in 
revenue because even simplified provisions likely would have some 
associated noncompliance. Nevertheless, the estimate suggests that 
simplification could have important tax gap consequences, particularly 
if simplification also accounted for any noncompliance that arises 
because of complexity on the income side of the tax gap for 
individuals.[Footnote 20] 

Despite the potential benefits that simplification may yield, these 
credits and deductions serve purposes that Congress has judged to be 
important to advance federal goals. Eliminating them or consolidating 
them likely would be complicated, and would likely create winners and 
losers. Elimination also could conflict with other objectives such as 
encouraging certain economic activity or improving equity. 

Similar trade-offs exist with possible fundamental tax reforms that 
would move away from an income tax system to some other system, such as 
a consumption tax, national sales tax, or value added tax. Fundamental 
tax reform would most likely result in a smaller tax gap if the new 
system has few tax preferences or complex tax code provisions and if 
taxable transactions are transparent. However, these characteristics 
are difficult to achieve in any system and experience suggests that 
simply adopting a fundamentally different tax system may not by itself 
eliminate any tax gap.[Footnote 21] Any tax system could be subject to 
noncompliance, and its design and operation, including the types of 
tools made available to tax administrators, will affect the size of any 
corresponding tax gap. Further, the motivating forces behind tax reform 
likely include factors beyond tax compliance, such as economic 
effectiveness, equity, and burden, which could in some cases carry 
greater weight in designing an alternative tax system than ensuring the 
highest levels of compliance. 

Providing IRS with Additional Enforcement Tools Potentially Could 
Improve Compliance Significantly, but Identifying and Designing Such 
Tools Can Be Challenging: 

Changing the tax laws to provide IRS with additional enforcement tools, 
such as expanded tax withholding and information reporting, could also 
reduce the tax gap by many billions of dollars, particularly with 
regard to underreporting--the largest segment of the tax gap. Tax 
withholding promotes compliance because employers or other parties 
subtract taxes owed from a taxpayer's income and remit them to IRS. 
Information reporting tends to lead to high levels of compliance 
because income taxpayers earn is transparent to them and IRS. In both 
cases, high levels of compliance tend to be maintained over time. Also, 
withholding and information reporting help IRS to better identify 
noncompliant taxpayers and prioritize contacting them, which enables 
IRS to better allocate its resources. However, designing new 
withholding or information reporting requirements to address 
underreporting can be challenging given that many types of income are 
already subject to at least some form of withholding or information 
reporting, underreporting exists in varied forms, and the requirements 
could impose costs and burdens on third parties. 

Figure 1 shows how much voluntary reporting compliance improves for 
income subject to withholding or information reporting. Once 
withholding or information reporting requirements are in place for 
particular types of income, compliance tends to remain high over time. 
For example, for wages and salaries, which are subject to tax 
withholding and substantial information reporting, the percentage of 
income that taxpayers misreport has consistently been measured at 
around 1 percent over time. 

Figure 1: Individual Net Income Misreporting Categorized by the Extent 
of Income Subject to Withholding and Information Reporting, Tax Year 
2001: 

[See PDF for image] 

Source: IRS. 

[End of figure] 

In the past, we have identified a few specific areas where additional 
withholding or information reporting requirements could serve to 
improve compliance: 

* Require more data on information returns dealing with capital gains 
income from securities sales. Recently, we reported that an estimated 
36 percent of taxpayers misreported their capital gains or losses from 
the sale of securities, such as corporate stocks and mutual 
funds.[Footnote 22] Further, around half of the taxpayers who 
misreported did so because they failed to report the securities' cost, 
or basis, sometimes because they did not know the securities' basis or 
failed to take certain events into account that required them to adjust 
the basis of their securities. When taxpayers sell securities like 
stock and mutual funds through brokers, the brokers are required to 
report information on the sale, including the amount of gross proceeds 
the taxpayer received; however, brokers are not required to report 
basis information for the sale of these securities. We found that 
requiring brokers to report basis information for securities sales 
could improve taxpayers' compliance in reporting their securities gains 
and losses and help IRS identify noncompliant taxpayers. However, we 
were unable to estimate the extent to which a basis reporting 
requirement would reduce the capital gains tax gap because of 
limitations with the compliance data on capital gains and because 
neither IRS nor we know the portion of the capital gains tax gap 
attributed to securities sales. 

* Requiring tax withholding and more or better information return 
reporting on payments made to independent contractors. Past IRS data 
have shown that independent contractors report 97 percent of the income 
that appears on information returns, while contractors that do not 
receive these returns report only 83 percent of income. We have also 
identified other options for improving information reporting for 
independent contractors, including increasing penalties for failing to 
file required information returns, lowering the $600 threshold for 
requiring such returns, and requiring businesses to report separately 
on their tax returns the total amount of payments to independent 
contractors.[Footnote 23] 

* Requiring information return reporting on payments made to 
corporations. Unlike payments made to sole proprietors, payments made 
to corporations for services are generally not required to be reported 
on information returns. IRS and GAO[Footnote 24] have contended that 
the lack of such a requirement leads to lower levels of compliance for 
small corporations. Although Congress has required federal agencies to 
provide information returns on payments made to contractors since 
1997,[Footnote 25] payments made by others to corporations are 
generally not covered by information returns. 

Information reporting helps IRS to better allocate its resources to the 
extent that it helps IRS better identify noncompliant taxpayers and the 
potential for additional revenue that could be obtained by contacting 
these taxpayers. For example, IRS officials told us that receiving 
information on basis for taxpayers' securities sales would allow IRS to 
determine more precisely taxpayers' income for securities sales through 
its document matching programs and would allow it to identify which 
taxpayers who misreported securities income have the greatest potential 
for additional tax assessments. Similarly, IRS could use basis 
information to improve both aspects of its examination program-- 
examinations of tax returns through correspondence and examinations of 
tax returns face to face with the taxpayer. Currently, capital gains 
issues are too complex and time consuming for IRS to examine through 
correspondence. However, IRS officials told us that receiving cost 
basis information might enable IRS to examine noncompliant taxpayers 
through correspondence because it could productively select tax returns 
to examine. Also, having cost basis information could help IRS identify 
the best cases to examine face to face, making the examinations more 
productive while simultaneously reducing the burden imposed on 
compliant taxpayers who otherwise would be selected for examination. 

Withholding and information reporting lead to high levels of 
compliance. Designing new requirements to address underreporting would 
need to address the challenge that many types of income, including 
wages and salaries, dividend and interest income, and income from 
pensions and Social Security are already subject to withholding or 
substantial information reporting. Also, challenges arise in 
establishing new withholding or information reporting requirements for 
certain other types of income that are extensively underreported. Such 
underreporting may be difficult to determine because of complex tax 
laws or transactions or the lack of a practical and reliable third- 
party source to provide information on the taxable income. 

For example, while withholding or information reporting mechanisms on 
nonfarm sole proprietor and informal supplier income[Footnote 26] would 
likely improve their compliance, comprehensive mechanisms that are 
practical and effective are difficult to identify. As shown in figure 
1, this income is not subject to information reporting, and these 
taxpayers misreported about half of the income they earned for tax year 
2001. Informal suppliers by definition receive income in an informal 
manner through services they provide to a variety of individual 
citizens or small businesses. Whereas businesses may have the capacity 
to perform withholding and information reporting functions for their 
employees, it may be challenging to extend withholding or information 
reporting responsibilities to the individual citizens that receive 
services, who may not have the resources or knowledge to comply with 
such requirements. 

Finally, implementing tax withholding and information reporting 
requirements generally imposes costs and burdens on the businesses that 
must implement them, and, in some cases, on taxpayers. For example, 
expanding information reporting on securities sales to include basis 
information will impose costs on the brokers who would track and report 
the information. Further, trying to close the entire tax gap with these 
enforcement tools could entail more intrusive recordkeeping or 
reporting than the public is willing to accept. 

The administration's proposed budget for fiscal year 2008 has 16 
legislative proposals on tax gap reduction of which 7 relate to 
expanded information reporting.[Footnote 27] Two of these proposals 
involve information reporting on payments to corporations and on the 
cost basis of security sales, which we discussed earlier in this 
section of the testimony. The administration also proposes requiring a 
certified tax identification number from nonemployee service providers 
(contractors), increased information reporting for certain government 
payments for property and services, and increased information return 
penalties. We have done past work related to these proposals and 
suggested them as options for reducing the tax gap.[Footnote 28] The 
remaining 2 proposals would expand broker information reporting and 
require information reporting on merchant card payment reimbursements. 

The 7 proposals relating to information reporting account for virtually 
all the revenue that the budget request's 16 tax gap legislative 
proposals are projected to raise. The 16 proposals are expected to 
raise about $29 billion over 10 years, or about 1 percent per year of 
the 2001 net tax gap amount of $290 billion. About 98 percent of the 
$29 billion would come from the information reporting proposals. About 
85 percent would come from 3 of them--those relating to payments to 
corporations, basis reporting on security sales, and merchant payment 
card reimbursements. 

Devoting Additional Resources to Enforcement Likely Could Reduce the 
Tax Gap, but to What Extent Is Difficult to Predict: 

Devoting more resources to enforcement has the potential to help reduce 
the tax gap by billions of dollars, as IRS would be able to expand its 
enforcement efforts to reach a greater number of potentially 
noncompliant taxpayers. However, determining the appropriate level of 
enforcement resources to provide IRS requires taking into account many 
factors, such as how effectively and efficiently IRS is currently using 
its resources, how to strike the proper balance between IRS's taxpayer 
service and enforcement activities, and competing federal funding 
priorities. If Congress were to provide IRS more enforcement resources, 
the amount of the tax gap that could be reduced depends in part on the 
size of any increase in IRS's budget, how IRS would manage any 
additional resources, and the indirect increase in taxpayers' voluntary 
compliance that would likely result from expanded IRS enforcement. 

Given resource constraints, IRS is unable to contact millions of 
additional taxpayers for whom it has evidence of potential 
noncompliance.[Footnote 29] With additional resources, IRS would be 
able to assess and collect additional taxes and further reduce the tax 
gap. In 2002, IRS estimated that a $2.2 billion funding increase would 
allow it to take enforcement actions against potentially noncompliant 
taxpayers it identifies but cannot contact and would yield an estimated 
$30 billion in revenue.[Footnote 30] For example, IRS estimated that it 
contacted about 3 million of the over 13 million taxpayers it 
identified as potentially noncompliant through its matching of tax 
returns to information returns. IRS estimated that contacting the 
additional 10 million potentially noncompliant taxpayers it identified, 
at a cost of about $230 million, could yield nearly $7 billion in 
potentially collectible revenue. We did not evaluate the accuracy of 
the estimate, and as will be discussed below, many factors suggest that 
it is difficult to estimate reliably net revenue increases that might 
come from additional enforcement efforts.[Footnote 31] 

Although additional enforcement funding has the potential to reduce the 
tax gap, the extent to which it would help depends on several factors. 
First, and perhaps most obviously, the amount of tax gap reduction 
would depend in part on the amount of additional resources. The degree 
to which revenues would increase from expanded enforcement depends on 
many variables, such as how quickly IRS can ramp up efforts, how well 
IRS selects the best cases to be worked, and how taxpayers react to 
enforcement efforts. Estimating those revenue increases would require 
assumptions about these and other variables. Because actual experience 
is likely to diverge from those assumptions, the actual revenue 
increases are likely to differ from the estimates. The lack of reliable 
key data compounds the difficulty of estimating the likely revenues. To 
the extent possible, obtaining better data on key variables would 
provide a better understanding of the likely results with any increased 
enforcement resources. 

With additional resources for enforcement, IRS would be able to assess 
and collect additional taxes, but the related tax gap reductions may 
not be immediate. If IRS uses the resources to hire more enforcement 
staff, the reductions may occur gradually as IRS is able to hire and 
train the staff. Also, several years can elapse after IRS assesses 
taxes before it actually collects these taxes. 

Similarly, the amounts of taxes actually collected can vary 
substantially from the related tax amounts assessed through enforcement 
actions by the type of tax or taxpayer involved. In a 1998 report, we 
found that 5 years after taxes were assessed against individual 
taxpayers with business income, 48 percent of the assessed taxes had 
been collected, whereas for the largest corporate taxpayers, 97 percent 
of assessed taxes had been collected.[Footnote 32] 

These various factors need to be taken into account in estimating 
revenue to be obtained from increased funding. In doing such estimates 
for its fiscal year 2007 budget, IRS accounted for several factors, 
including opportunity costs because of training, which draws 
experienced enforcement personnel away from the field; differences in 
average enforcement revenue obtained per full-time employee by 
enforcement activity; and differences in the types and complexity of 
cases worked by new hires and experienced hires. IRS forecasted that in 
the first year after expanding enforcement activities, the additional 
revenue to be collected is less than half the amount to be collected in 
later years. This example underscores the logic that if IRS is to 
receive a relatively large funding increase, it likely would be better 
to provide it in small but steady amounts. 

The amount of tax gap reduction likely to be achieved from any budget 
increase also depends on how well IRS can use information about 
noncompliance to manage the additional resources. Because IRS does not 
have compliance data for some segments of the tax gap and others are 
based on old data, IRS cannot easily track the extent to which 
compliance is improving or declining. IRS also has concerns with its 
information on whether taxpayers unintentionally or intentionally fail 
to comply with the tax laws. Knowing the reasons for taxpayer 
noncompliance can help IRS decide whether its efforts to address 
specific areas of noncompliance should focus on nonenforcement 
activities, such as improved forms or publications, or enforcement 
activities to pursue intentional noncompliance. To the extent that 
compliance data are outdated and IRS does not know the reason for 
taxpayer noncompliance, IRS may be less able to target resources 
efficiently to achieve the greatest tax gap reduction at the least 
taxpayer burden. 

IRS has taken important steps to better ensure efficient allocation and 
use. For example, the NRP study has provided better data on which 
taxpayers are most likely to be noncompliant. IRS is using the data to 
improve its audit selection processes in hopes of reducing the number 
of audits that result in no change, which should reduce unnecessary 
burden on compliant taxpayers and increase enforcement staff 
productivity (as measured by direct enforcement revenue). 

As part of an effort to make the best use of its enforcement resources, 
IRS has developed rough measures of return on investment in terms of 
tax revenue that it assesses from uncovering noncompliance. Generally, 
IRS cites an average return on investment for enforcement of 4:1, that 
is, IRS estimates that it collects $4 in revenue for every $1 of 
funding. Where IRS has developed return on investment estimates for 
specific programs, it finds substantial variation depending on the type 
of enforcement action. For instance, the ratio of estimated tax revenue 
gains to additional spending for pursuing known individual tax debts 
through phone calls is 13:1, versus a ratio of 32:1 for matching the 
amount of income taxpayers report on their tax returns to the income 
amounts reported on information returns. In addition to returns on 
investment estimates being rough, IRS lacks information on the 
incremental returns on investment from pursuing the "next best case" 
for some enforcement programs. It is the marginal revenue gain from 
these cases that matters in estimating the direct revenue from expanded 
enforcement. Developing such measures is difficult because of 
incomplete information on all the costs and all the tax revenue 
ultimately collected from specific enforcement efforts. Because IRS's 
current estimates of the revenue effects of additional funding are 
imprecise, the actual revenue that might be gained from expanding 
different enforcement efforts is subject to uncertainty. 

Given the variation in estimated returns on investment for different 
types of IRS compliance efforts, the amount of tax gap reduction that 
may be achieved from an increase in IRS's resources would depend on how 
IRS allocates the increase. Although it might be tempting to allocate 
resources heavily toward areas with the highest estimated return, 
allocation decisions must take into account diverse and difficult 
issues. For instance, although one enforcement activity may have a high 
estimated return, that return may drop off quickly as IRS works its way 
through potential noncompliance cases. In addition, IRS dedicates 
examination resources across all types of taxpayers so that all 
taxpayers receive some signal that noncompliance is being addressed. 
Further, issues of fairness can arise if IRS focuses its efforts only 
on particular groups of taxpayers. 

Beyond direct tax revenue collection, expanded enforcement efforts 
could reduce the tax gap even more, as widespread agreement exists that 
IRS enforcement programs have an indirect effect through increases in 
voluntary tax compliance.[Footnote 33] The precise magnitude of the 
indirect effects of enforcement is not known with a high level of 
confidence given challenges in measuring compliance; developing 
reasonable assumptions about taxpayer behavior; and accounting for 
factors outside of IRS's actions that can affect taxpayer compliance, 
such as changes in tax law. However, several research studies have 
offered insights to help better understand the indirect effects of IRS 
enforcement on voluntary tax compliance and show that they could exceed 
the direct effect of revenue obtained.[Footnote 34] 

As table 2 shows, the administration's budget request for fiscal year 
2008 proposes additional revenue-producing initiatives, legislative 
proposals, and non-revenue-producing initiatives. The revenue- 
producing initiatives generally would fund additional staff to enforce 
tax laws; the legislative proposals include, for example, new 
information return requirements that would increase revenue; and the 
non-revenue-producing initiatives generally would fund infrastructure 
and Business Systems Modernization changes to support IRS operations. 

Table 2: Cost and Estimated Revenue of IRS Tax Gap Proposals for Fiscal 
Years 2008 through 2010: 

Dollars in millions. 

Type of proposal: Revenue-producing initiatives; 
Cost of proposal: Fiscal year 2008: $198; 
Cost of proposal: Fiscal year 2009: $163; 
Cost of proposal: Fiscal year 2010: $163; 
Estimated revenue from proposal: Fiscal year 2008: $317; 
Estimated revenue from proposal: Fiscal year 2009: $526; 
Estimated revenue from proposal: Fiscal year 2010: $699. 

Type of proposal: Legislative proposals; 
Cost of proposal: Fiscal year 2008: 23; 
Cost of proposal: Fiscal year 2009: 23; 
Cost of proposal: Fiscal year 2010: 23; 
Estimated revenue from proposal: Fiscal year 2008: 378; 
Estimated revenue from proposal: Fiscal year 2009: 1,171; 
Estimated revenue from proposal: Fiscal year 2010: 1,898. 

Type of proposal: Non-revenue-producing initiatives; 
Cost of proposal: Fiscal year 2008: 188; 
Cost of proposal: Fiscal year 2009: 168; 
Cost of proposal: Fiscal year 2010: 168; 
Estimated revenue from proposal: Fiscal year 2008: 0; 
Estimated revenue from proposal: Fiscal year 2009: 0; 
Estimated revenue from proposal: Fiscal year 2010: 0. 

Type of proposal: Total; 
Cost of proposal: Fiscal year 2008: $410; 
Cost of proposal: Fiscal year 2009: $355; 
Cost of proposal: Fiscal year 2010: $355; 
Estimated revenue from proposal: Fiscal year 2008: $695; 
Estimated revenue from proposal: Fiscal year 2009: $1,697; 
Estimated revenue from proposal: Fiscal year 2010: $2,597. 

Source: GAO (analysis); IRS and Department of the Treasury (data). 

Note: Figures may not sum to totals because of rounding. Data are from 
IRS and from Treasury's February 2007 General Explanations of the 
Administration's Fiscal Year 2008 Revenue Proposals. 

[End of table] 

Over the 3 years, the requested funding decreases while the estimated 
resulting revenue increases. About $410 million is requested for fiscal 
year 2008 to fund all of these initiatives, which are estimated to 
bring in about $695 million in increased revenue that year. The 
estimated cost for the initiatives declines to $355 million in fiscal 
years 2009 and 2010 and the projected revenues increase to about $2.6 
billion in 2010. Costs decline due to start up costs applying only in 
fiscal year 2008. Revenues increase in part due to improved annual 
returns from the hiring, training, and deployment of additional staff, 
but more so due to the phase in of the legislative proposals, 
particularly the information reporting requirements. The legislative 
proposals alone are estimated to produce $1.9 billion of the $2.6 
billion total additional revenues expected to come from the 
administration's budget proposals in fiscal year 2010. The revenue 
effects of the revenue-producing initiatives exclude the likely 
deterrent effect from IRS enforcement programs as well as any 
improvement in voluntary compliance due to improved taxpayer services. 

The revenues expected from these initiatives are small compared to the 
estimated $290 billion net tax gap for tax year 2001. For instance, all 
of the revenue-producing initiatives coming largely from additional 
enforcement staffing are expected to yield about $699 million in fiscal 
year 2010, or about one-quarter of 1 percent of the tax year 2001 net 
tax gap. In 2010, the total estimated increased revenues from both the 
revenue-producing and legislative initiatives, or about $2.6 billion, 
is about 0.9 percent of the 2001 net tax gap. 

Concluding Observations: 

When taxpayers do not pay all of their taxes, honest taxpayers carry a 
greater burden to fund government programs and the nation is less able 
to address its long-term fiscal challenges. Thus, reducing the tax gap 
is important, even though closing the entire tax gap is neither 
feasible nor desirable because of costs and intrusiveness. All of the 
approaches I have discussed have the potential to reduce the tax gap 
alone or in combination, and no single approach is clearly and always 
superior to the others. As a result, IRS needs a strategy to attack the 
tax gap on multiple fronts with multiple approaches. The various 
proposals in the administration's budget request raise modest dollar 
amounts compared to the size of the tax gap. This underscores the 
likelihood that a wide variety of efforts will be needed to make 
significant progress in addressing the tax gap. We look forward to 
seeing the administration's expanded outline of steps it will be 
taking. 

Mr. Chairman and Members of the Committee, this concludes my testimony. 
I would be happy to answer any question you may have at this time. 

Contact and Acknowledgments: 

For further information on this testimony, please contact Michael 
Brostek on (202) 512-9110 or brostekm@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this testimony. Individuals making key contributions 
to this testimony include Thomas Short, Assistant Director; Jeffrey 
Arkin; Elizabeth Fan; Ronald Jones; Lawrence Korb; and Ellen Rominger. 

FOOTNOTES 

[1] Throughout this statement, references to the tax gap refer to the 
gross tax gap unless otherwise noted. 

[2] Information reporting involves the filing of information returns 
with IRS and taxpayers that contain information on certain 
transactions, such as wage and salary information employers report to 
employees and IRS through Form W-2. 

[3] An example of tax withholding is when employers withhold taxes on 
the wages that employees earn and remit them to IRS. 

[4] GAO, Tax Compliance: Multiple Approaches Are Needed to Reduce the 
Tax Gap, GAO-07-391T (Washington, D.C.: Jan. 23, 2007); Tax Compliance: 
Opportunities Exist to Reduce the Tax Gap Using a Variety of 
Approaches, GAO-06-1000T (Washington, D.C.: July 26, 2006); Tax Gap: 
Making Significant Progress in Improving Tax Compliance Rests on 
Enhancing Current IRS Techniques and Adopting New Legislative Actions, 
GAO-06-453T (Washington, D.C.: Feb. 15, 2006); Tax Gap: Multiple 
Strategies, Better Compliance Data, and Long-Term Goals Are Needed to 
Improve Taxpayer Compliance, GAO-06-208T (Washington, D.C.: Oct. 26, 
2005); Tax Compliance: Better Compliance Data and Long-term Goals Would 
Support a More Strategic IRS Approach to Reducing the Tax Gap, GAO-05-
753 (Washington, D.C.: July 18, 2005); and Tax Compliance: Reducing the 
Tax Gap Can Contribute to Fiscal Sustainability but Will Require a 
Variety of Strategies, GAO-05-527T (Washington, D.C.: Apr. 14, 2005). 

[5] Taxpayers who receive filing extensions, pay their full tax 
liability by payment due dates, and file returns prior to extension 
deadlines are considered to have filed on time. 

[6] For these types of noncompliance, IRS maintains that the data are 
either difficult to collect, imprecise, or unavailable. 

[7] For a more detailed discussion about data sources and methodologies 
used in estimating the tax gap, see GAO-05-753. 

[8] In some instances, the amount of the tax gap can change without a 
corresponding change in the level of compliance. For example, a 
reduction in marginal tax rates could result in a smaller tax gap even 
if the level of compliance remains unchanged because the amount of 
taxes that should be paid has been reduced. The tax gap would also tend 
to increase over time, even if the rate of taxpayer compliance remained 
unchanged, because of inflation. 

[9] GAO, Internal Revenue Service: Assessment of the Interim Results of 
the 2006 Filing Season and Fiscal Year 2007 Budget Request, GAO-06-499T 
(Washington, D.C.: Apr. 27, 2006). 

[10] GAO-05-753. 

[11] GAO, Student Aid and Postsecondary Tax Preferences: Limited 
Research Exists on the Effectiveness of Tools to Assist Students and 
Families through Title IV Student Aid and Tax Preferences, GAO-05-684 
(Washington, D.C.: July 29, 2005). 

[12] GAO, Paid Tax Return Preparers: In a Limited Study, Chain 
Preparers Made Serious Errors, GAO-06-563T (Washington, D.C.: Apr. 4, 
2006). 

[13] U.S. Congress, Joint Committee on Taxation, Study of the Overall 
State of the Federal Tax System, vol. II, 125-6 (April 2001). 

[14] IRS measured the extent of noncompliance with the earned income 
tax credit in a study separate from NRP. 

[15] GAO-06-208T. 

[16] Internal Revenue Service, Taxpayer Advocate Service, National 
Taxpayer Advocate 2004 Annual Report to Congress (Washington, D.C.: 
Dec. 31, 2004). 

[17] The Congressional Budget and Impoundment Control Act of 1974, Pub. 
L. No. 93-344, § 3, 88 Stat. 299 (July 12, 1974) (codified at 2 U.S.C. 
§ 622(3)). 

[18] GAO, Government Performance and Accountability: Tax Expenditures 
Represent a Substantial Federal Commitment and Need to Be Reexamined, 
GAO-05-690 (Washington, D.C.: Sept. 23, 2005). 

[19] Summing tax expenditure estimates does not take into account 
interactions between individual provisions. 

[20] The tax gap for underreported individual income taxes exceeded 
$150 billion for tax year 2001. However, IRS does not have data on how 
much of this noncompliance arose because of complexity. 

[21] For example, in a 2004 report, the National Audit Office in the 
United Kingdom reported on the 15.7 percent gap for the value added 
tax, which was introduced three decades earlier. 

[22] GAO, Capital Gains Tax Gap: Requiring Brokers to Report Securities 
Cost Basis Would Improve Compliance if Related Challenges Are 
Addressed, GAO-06-603 (Washington, D.C.: June 13, 2006). 

[23] GAO, Tax Administration: Approaches for Improving Independent 
Contractor Compliance, GAO/GGD-92-108 (Washington, D.C.: July 23, 
1992). 

[24] GAO, Tax Administration: Benefits of a Corporate Document Matching 
Program Exceed the Costs, GAO/GGD-91-118 (Washington, D.C.: Sept. 27, 
1991). 

[25] Taxpayer Relief Act of 1997, Pub. L. No. 105-34 (1997). 

[26] Nonfarm proprietors are self-employed individuals other than 
farmers who should file Schedule C with their individual tax returns to 
report profits and losses from their businesses. Sole proprietors 
include those who provide services, such as doctors or accountants; 
produce goods, such as manufacturers; and sell goods at fixed 
locations, such as car dealers and grocers. Informal suppliers are sole 
proprietors who work alone or with few workers and, by definition, 
operate in an informal manner. Informal suppliers include those who 
make home repairs, provide child care, or sell goods at roadside 
stands. These taxpayers should report business profits or losses on 
Schedule C. 

[27] In general, the other 9 proposals involve e-filing, clarifying 
employment tax liability for employee leasing companies and under 
collection due process procedures, sharing information related to the 
national directory of new hires and prison tax scams, making repeated 
and willful tax nonfiling a felony, and expanding IRS's penalty 
authority in certain areas. 

[28] GAO/GGD-92-108; Tax Administration: Federal Agencies Should Report 
Service Payments Made to Corporations, GAO/GGD-92-130 (Washington, 
D.C.: Sept. 22, 1992), and Tax Gap: Many Actions Taken, but a Cohesive 
Compliance Strategy Needed, GAO/GGD-94-123 (Washington, D.C.: May 11, 
1994). 

[29] For examples, see GAO, Tax Administration: Impact of Compliance 
and Collection Program Declines on Taxpayers, GAO-02-674 (Washington, 
D.C.: May 22, 2002); High Risk Series: An Update, GAO-05-207 
(Washington, D.C.: January 2005); and our tax gap products cited 
earlier in this statement, GAO-06-1000T, GAO-06-453T, GAO-06-208T, GAO-
05-753, and GAO-05-527T. 

[30] Commissioner of Internal Revenue Charles O. Rossotti, Report to 
the IRS Oversight Board: Assessment of IRS and the Tax System, October 
2002. 

[31] The overall tax gap has many components. Thus, if the tax gap in a 
specific area is reduced either through congressional actions like 
simplifying provisions or through IRS actions, the size of the overall 
gap may not be reduced if other portions of the gap increase. 

[32] GAO, Tax Administration: IRS Measures Could Provide a More 
Balanced Picture of Audit Results and Costs, GAO/GGD-98-128 
(Washington, D.C.: June 23, 1998). 

[33] Two types of indirect effect are (1) the increase in voluntary 
compliance in the larger population resulting from examinations or 
other enforcement and nonenforcement actions on targeted taxpayers, and 
(2) the increase in voluntary compliance of the targeted taxpayer in 
subsequent years. 

[34] Economists have estimated the indirect effect of an examination on 
voluntary compliance to range from 6 to 12 times the amount of proposed 
tax adjustments. See Alan H. Plumley, The Determinants of Individual 
Income Tax Compliance: Estimating The Impacts of Tax Policy, 
Enforcement, and IRS Responsiveness, Publication 1916 (Rev. 11-96) 
(Washington, D.C.: November 1996), 2, 35-36; Jeffrey A. Dubin, Michael 
J. Graetz, and Louis L. Wilde, "The Effect of Audit Rates on the 
Federal Individual Income Tax, 1977-1986," National Tax Journal, vol. 
43 (1990), 395, 396, 405; and Jeffrey A. Dubin, "Criminal Investigation 
Enforcement Activities and Taxpayer Noncompliance" (paper written for 
the IRS Research Conference, June 2004), http://www.irs.gov/pub/irs-
soi/04dubin.pdf (downloaded July 1, 2005). 

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