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United States Government Accountability Office: 
GAO: 

Testimony: 

Before the Subcommittee on Oversight, Committee on Ways and Means, 
House of Representatives: 

For Release on Delivery: 
Expected at 10:30 a.m. EDT: 
Wednesday, May 25, 2011: 

Tax Refunds: 

Enhanced Prerefund Compliance Checks Could Yield Significant Benefits: 

Statement of Michael Brostek, Director: 
Strategic Issues: 

GAO-11-691T: 

GAO Highlights: 

Highlights of GAO-11-691T, a testimony before the Subcommittee on 
Oversight, Committee on Ways and Means, House of Representatives. 

Why GAO Did This Study: 

In 2010, the Internal Revenue Service (IRS) processed about 137 
million individual income tax returns and issued 107 million refunds 
totaling over $312 billion. The compliance checks it performs before 
refunds are issued thus could affect millions of taxpayers and 
billions of dollars of refunds by identifying taxpayers who overclaim 
or underclaim tax benefits to which they are entitled. Math error 
authority (MEA) is just one example of the prerefund compliance checks 
that IRS uses. During 2010, IRS sent taxpayers 8.4 million notices for 
almost 10.6 million math errors identified on their 2009 individual 
tax returns. 

GAO’s statement today will focus on three key areas: (1) prerefund 
checks and their benefits, (2) how those checks can be enhanced 
immediately, and (3) how they may be enhanced in the future. It is 
mostly based on GAO’s previous work issued from 2008 through 2011, 
including an interim report on IRS’s 2011 tax filing season, and our 
ongoing analysis of the 2011 filing season. 

What GAO Found: 

Prerefund compliance checks enable IRS to help confirm taxpayers’ 
identity, quickly and efficiently correct some errors with virtual 
certainty, and identify and audit some returns before refunds are 
issued. Math error checks are among the most beneficial of these 
checks for both IRS and taxpayers. For example, they have the 
potential to deter billions of dollars in erroneous refunds, 
especially for refundable tax credits that have increasingly been 
enacted and that have resulted in significant overclaimed refunds and 
fraudulent claims. Taxpayers benefit from prerefund checks in several 
ways, including that IRS identifies those underclaiming benefits. Last 
year GAO reported that IRS corrected about 7.7 million errors 
associated with the Making Work Pay credit, including about 60 percent 
in the taxpayers’ favor, meaning that taxpayers received larger 
refunds (or had lower taxes due) than they had anticipated. For almost 
a century, Congress has been expanding IRS’s MEA on a case-by-case 
basis. In 2010, GAO suggested that authorizing the use of MEA on a 
broader basis with appropriate controls to protect taxpayer rights 
could help IRS immediately address compliance problems with newly 
created tax credits. In the absence of broader MEA, from 2008 through 
2011, GAO also suggested that Congress expand MEA for more limited 
purposes as shown below. 

Table: GAO Math Error Authority Matters for Congressional 
Consideration: 

Matter for consideration: Provide IRS with math error authority (MEA) 
to use prior years’ tax return information to ensure that taxpayers do 
not improperly claim credits or deductions in excess of applicable 
lifetime limits; 
Status (May 2011): Not yet enacted. 

Matter for consideration: Provide IRS with MEA to use prior years’ tax 
return information to automatically verify taxpayers’ compliance with 
the number of years the Hope credit can be claimed; 
Status (May 2011): Not yet enacted. 

Matter for consideration: Provide IRS with MEA to (1) use the prior 
year’s tax return information to automatically verify compliance with 
the 2008 First-Time Homebuyer Credit payback provision and (2) ensure 
that homebuyers do not improperly claim the credit in multiple years; 
Status (May 2011): Enacted in Public Law 111-92. 

Matter for consideration: Provide IRS with MEA to identify and correct 
returns with ineligible (1) individual retirement account (IRA) “catch-
up” contributions and (2) contributions to traditional IRAs from 
taxpayers over age 70½; 
Status (May 2011): Not yet enacted. 

Source: GAO. 

[End of table] 

Longer term, other IRS initiatives, such as matching information 
returns to tax returns during the filing season and leveraging new 
paid preparer requirements, could enhance compliance before refunds 
are issued. One prerequisite would be a major reworking of some 
fundamental IRS computer systems. 

What GAO Recommends: 

GAO makes no new recommendations in this testimony but describes prior 
matters for Congress to consider in granting IRS expanded MEA. 

View [hyperlink, http://www.gao.gov/products/GAO-11-691T] or key 
components. For more information, contact Michael Brostek at (202) 512-
9110 or brostekm@gao.gov. 

[End of section] 

Chairman Boustany, Ranking Member Lewis, and Members of the 
Subcommittee: 

Thank you for the opportunity to be here today to discuss the Internal 
Revenue Service's (IRS) prerefund compliance checks and the tools used 
as part of these checks. 

To provide an idea of the universe that these checks could affect, in 
2010, IRS processed about 137 million individual income tax returns 
and issued 107 million refunds totaling over $312 billion. Its 
compliance checks thus could affect millions of taxpayers and billions 
of dollars of refunds by identifying taxpayers who overclaim the 
amount due to them and taxpayers who underclaim tax benefits to which 
they are entitled. 

Before processing refunds, IRS checks returns for clerical and 
mathematical errors and conducts some additional checks on the 
information presented in the return. Math error authority (MEA) is 
just one example of the prerefund compliance checks that IRS uses. 
[Footnote 1] In 2010, IRS sent 8.4 million notices to taxpayers for 
almost 10.6 million math errors identified on their 2009 tax year 
returns. 

We have long highlighted the importance of improving IRS's prerefund 
compliance checks as a means to improve compliance while minimizing 
taxpayer burden. In 1998, we found that inadequate controls over 
refunds was a material weakness that could adversely affect IRS's 
ability to record, process, summarize, and report financial data. 
[Footnote 2] We continue to believe that enhanced preventive controls 
are keys to improving IRS's ability to correct taxpayer errors by 
preventing the disbursement of erroneous refunds, thereby saving the 
federal government potentially billions of dollars. 

My statement today will focus on three key areas: (1) prerefund checks 
and their benefits, (2) how those checks can be enhanced immediately, 
and (3) how they may be enhanced in the future. It is based mostly on 
our previous work issued from 2008 through 2011, including our interim 
report on IRS's 2011 tax filing season, and our ongoing analysis of 
the 2011 filing season.[Footnote 3] Those performance audits were 
conducted in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

Current Prerefund Checks Provide Significant Benefits: 

Prerefund compliance checks enable IRS to help confirm taxpayers' 
identities and ensure that returns have required information, quickly 
and efficiently correct certain errors with a virtual certainty of 
being right, identify and audit some returns even before refunds are 
completed, and help detect possible fraud.[Footnote 4] Figure 1 shows 
IRS's prerefund process.[Footnote 5] 

Figure 1: Processing and Correcting Returns with Errors: 

[Refer to PDF for image: illustration] 

Return submitted electronically: 

1) IRS attempts to verify identity by automatically checking for 
mismatches between IRS systems' data and the return. If mismatch 
exists, return to preparer and/or taxpayer. 

2A) Processing system captures return data; go to #4; or: 

2B) Mismatches for returns that were filed on paper are forwarded to 
the Error Resolution System[A]. 

2C) In the Error Resolution System, IRS specialists correct or resolve 
issues for which IRS has math error authority. 

3) Automated computer programs check for math errors, cases to audit, 
and possible fraud. 

4) Math error processing: Errors found; Math errors corrected. 

5) If IRS does not have math error authority to correct the error, the 
return is identified for potential audit. 

6) If noncompliance is detected, IRS sends a statutory notice of 
deficiency to the taxpayer. 

7) Return data are posted to IRS's master file: If IRS corrected a 
math error, it sends a notice to the taxpayer. 

Return submitted on paper: 

1) IRS examiners screen returns to ensure that all data needed to 
process the return are present, including Social Security number, 
taxpayer identification number, name, and address. If additional 
information is needed, IRS sends correspondence to preparer and/or 
taxpayer. 

2) IRS examiners screen returns to ensure that all data needed to 
process the return are present, including Social Security number, 
taxpayer identification number, name, and address. 

3) Return data are manually transcribed. 

4) IRS attempts to verify identity by automatically checking for 
mismatches between IRS systems' data and the return. If mismatch 
exists, return to preparer and/or taxpayer. 

5A) Processing system captures return data; go to #7; or: 

5B) Mismatches for returns that were filed on paper are forwarded to 
the Error Resolution System[A]. 

5C) In the Error Resolution System, IRS specialists correct or resolve 
issues for which IRS has math error authority. 

6) Automated computer programs check for math errors, cases to audit, 
and possible fraud. 

7) Math error processing: Errors found; Math errors corrected. 

8) If IRS does not have math error authority to correct the error, the 
return is identified for potential audit. 

9) If noncompliance is detected, IRS sends a statutory notice of 
deficiency to the taxpayer. 

10) Return data are posted to IRS's master file: If IRS corrected a 
math error, it sends a notice to the taxpayer. 

Source: GAO analysis of IRS information. 

[A] IRS's Error Resolution System is generally used to correct errors 
on tax returns so that they can be processed or to change the amount 
of tax owed pursuant to math error authority before a refund is issued. 

[End of figure] 

Steps to Confirm Taxpayers' Identities and Ensure That Required 
Information Is Provided: 

When tax returns are first received by IRS, the initial process helps 
correct taxpayer identification errors and ensure taxpayers have 
filled in all fields that are required for IRS to process the return. 
The process differs slightly for electronically and paper filed 
returns. For electronic returns, IRS checks for possible mismatches 
among taxpayers' identity information, such as their names, Social 
Security numbers, and addresses. When mismatches occur, IRS rejects 
the tax return back to the taxpayer or paid preparer for possible 
correction. For paper returns, IRS staff review each return to ensure 
that all forms and data needed to process the return are present and 
may correspond with the taxpayer for missing information. IRS staff 
then transcribe data from the paper return into IRS computer systems 
and programming matches taxpayers' identity information if possible. 
Later on in the process, IRS staff may also correspond with taxpayers 
or their paid preparers to obtain other missing information, as well 
as research and correct certain errors that would affect processing 
the return, such as transposed numbers within Social Security numbers. 

Application of Computerized Filters: 

After initial errors are corrected, the return information is captured 
in IRS's tax return processing systems. At this point, IRS applies 
additional computerized filters. Some filters identify errors that can 
be corrected using IRS's MEA. Other filters identify errors that can 
be addressed through audits either before a complete refund is sent to 
the taxpayer or afterwards. Finally, still other filters identify 
possible cases of tax fraud. 

Math Error Authority Checks: 

When IRS's computer programs identify errors on returns that can be 
corrected with virtual certainty, those returns are forwarded to IRS's 
Error Resolution System (ERS). Despite the name, math errors encompass 
much more than simple arithmetic errors. They also include, for 
instance, identifying incorrect Social Security or other taxpayer 
identification numbers, problems with taxpayers' filing status or 
claiming of dependents, and missing schedules or forms. Some of these 
errors are detected from information included on the tax return 
itself, and some are detected by comparing information on the return 
to other internal IRS databases or databases of information obtained 
from others, such as the Social Security Administration. 

In ERS, IRS staff manually review the error and enter codes that then 
automatically generate a notice to the taxpayer that explains the 
error, identifies the revision in the taxpayer's refund amount--or 
possibly a new balance due to IRS, and instructs the taxpayer on how 
to respond if he or she disagrees with the change IRS has made. 

Prerefund and Postrefund Audits: 

When IRS filters identify an error not correctable with MEA, the 
return is placed in queue for possible prerefund or postrefund audit. 
Depending on available resources, IRS will audit a portion of these 
returns, generally through correspondence audits with taxpayers, 
before complete refunds are sent to the taxpayers. In some cases, IRS 
will send the taxpayers the portion of their refunds that was claimed 
correctly while withholding the portion that IRS considers likely to 
be in error. To the extent returns are not handled in prerefund 
audits, IRS will include them for possible postrefund audits. 

Fraud Investigations: 

Based on IRS's computer filters, IRS identifies some refund claims 
that may be fraudulent. These are forwarded to IRS's Criminal 
Investigation division. Those investigations may occur simultaneously 
as math error or audit corrections are being made to the return. In 
some cases, the investigation may be of a taxpayer and in other cases 
it may focus on a paid preparer or others who may be engaging in 
systematic fraud affecting more than one return. 

Benefits of Prerefund Checks: 

Collectively and individually, these prerefund checks have benefits 
for IRS and taxpayers. The initial checks on taxpayers' identities and 
completeness of returns help ensure that returns can be accepted and 
processed quickly for taxpayers. It also allows IRS to detect common 
errors or noncompliance such as if a taxpayer uses a false Social 
Security number to claim a dependent. 

Math error checks are among the most beneficial of the prerefund 
checks for both taxpayers and IRS. These checks have the potential to 
protect billions of dollars in federal revenue from being erroneously 
refunded to taxpayers, especially for refundable tax credits that have 
been increasingly enacted in recent years, as significant overclaimed 
refund amounts result, sometimes through fraudulent claims. For 
example, Congress enacted three different versions of the refundable 
First-Time Homebuyer Credit (FTHBC) but did not immediately provide 
IRS with MEA to automatically verify certain information.[Footnote 6] 
In 2009, we proposed that Congress grant MEA to IRS to conduct 
prerefund compliance checks to ensure that taxpayers do not claim the 
homebuyer credit in multiple years.[Footnote 7] We calculated that IRS 
prevented about $95 million in erroneous refunds in fiscal year 2010 
using this new authority. In addition, this and various other MEA 
provisions for the FTHBC granted to IRS after the credit was first 
enacted allowed IRS to deny approximately 350,000 erroneous claims in 
2010, thereby saving tax revenue and enabling IRS to use scarce 
enforcement resources elsewhere. If not denied, this large volume of 
erroneous claims would have roughly translated into a billion dollars 
or more in improper payments. 

IRS can use MEA to correct errors it identifies and send the corrected 
refund amount to the taxpayer instead of trying to recover 
overpayments after audit. In postrefund enforcement, IRS may not 
recover all funds that are owed, which may be especially true for 
cases of fraud, and may incur additional costs in attempting to 
collect the delinquent taxes. We have previously reported that prompt 
compliance checks are important because as unpaid taxes age, the 
likelihood of collecting all or part of the amounts owed decreases. 
[Footnote 8] 

For taxpayers, some MEA helps them receive tax benefits for which they 
are eligible by identifying individuals who underclaimed the benefits. 
For example, last year we reported that from January 1 through 
September 30, 2010, IRS corrected about 7.7 million errors associated 
with the Making Work Pay credit, including about 60 percent in the 
taxpayers' favor. These corrections meant that taxpayers received 
larger refunds (or had lower taxes due) than they had anticipated. 
[Footnote 9] 

If IRS conducts a prerefund audit, it holds disputed refund amounts 
until the taxpayer's proper tax liability can be determined and the 
audit is concluded. As with math error checks, prerefund audits are 
preferable because once a refund has been paid, IRS may be unable to 
collect all amounts due and can incur significant expenses in the 
collection of delinquent tax debts. For taxpayers, prerefund audits 
also minimize the possible interest expenses they would incur if the 
audits did not occur for months or more after their return was filed. 
Generally, taxpayers accrue interest on underpaid taxes from the date 
the tax becomes due. 

Finally, beginning fraud investigations as quickly as possible has 
several advantages for IRS. In general, the more quickly such 
investigations are begun, the more likely evidence will be available. 
To the extent that investigations lead to quick action, perpetrators 
of fraud may be stopped before they can continue their efforts through 
the filing season. An affirmative IRS investigative presence and 
successfully resolved cases may also deter some who would otherwise be 
tempted to engage in fraudulent activities. 

Prerefund Checks Can Be Enhanced: 

For almost a century, Congress has been expanding IRS's MEA on a case- 
by-case basis. Its most recent expansions were to help determine the 
eligibility for certain credits such as the FTHBC. The increase over 
time has resulted in the 13 existing MEA provisions shown in appendix 
I. 

Although Congress sometimes quickly extended MEA to address compliance 
issues with newly created tax credits, at times a round of initial 
errors occurred before IRS was able to obtain the new authority. We 
suggested in 2010 that authorizing the use of MEA on a broader basis 
rather than on a case-by-case basis, with appropriate controls to 
protect taxpayer rights, could minimize the danger of that happening 
in the future.[Footnote 10] In the past we identified benefits to IRS 
and taxpayers that could arise from broader MEA. I already mentioned 
some of these earlier, but, to summarize, broader MEA could: 

* enable IRS to correct all or nearly all returns where IRS identifies 
the noncompliance and the needed correction with virtual certainty, 
not just those it can address through other enforcement means; 

* be low cost and less intrusive and burdensome to taxpayers than 
audits; 

* ensure that taxpayers who are noncompliant on a particular issue are 
similarly treated, that is, that a greater portion of them are brought 
into compliance, not just those that IRS could otherwise address 
through other enforcement means; 

* enhance equity between compliant and noncompliant taxpayers because 
a greater portion of the noncompliant taxpayers would be brought into 
compliance; 

* provide a taxpayer service as it would generally allow noncompliant 
taxpayers to receive their refunds faster than if IRS had to address 
the error through some other compliance mechanism, have their returns 
corrected without penalty and before interest is accrued, and avoid 
time-consuming interaction with IRS under its other programs for 
resolving noncompliance; 

* help ensure that taxpayers receive the tax benefits for which they 
are eligible by identifying taxpayers who underclaim a tax benefit; 

* free up IRS resources to pursue other forms of noncompliance; and: 

* allow IRS to quickly address provisions arising from new and quickly 
moving initiatives like the American Recovery and Reinvestment Act of 
2009 (Pub. L. No. 111-5) without waiting for new MEA to go through the 
legislative process. 

While providing broad MEA is ideal, we have also suggested that 
Congress expand MEA for more limited purposes. As we recently 
reported, IRS does not have MEA to review prior year tax returns to 
ensure that taxpayers do not claim credits or deductions in excess of 
lifetime limits such as for residential energy credits.[Footnote 11] 
We have identified four specific cases where IRS could benefit from 
additional MEA, including for the FTHBC for which Congress granted 
authority. Expanding MEA should also provide many of the same benefits 
described above. Table 1 provides a summary of GAO's previous matters 
for congressional consideration for expanded MEA. 

Table 1: GAO Math Error Authority Matters for Congressional 
Consideration: 

1. Matter for consideration: Provide IRS with math error authority to 
use prior years' tax return information to ensure that taxpayers do 
not improperly claim credits or deductions in excess of applicable 
lifetime limits; 
Date of report: March 29, 2011; 
Disposition (as of May 2011): Not yet enacted; 
Source: GAO-11-481. 

2. Matter for consideration: Provide IRS with math error authority to 
use prior years' tax return information to automatically verify 
taxpayers' compliance with the number of years the Hope credit can be 
claimed; 
Date of report: December 10, 2009; 
Disposition (as of May 2011): Not yet enacted; 
Source: GAO-10-225. 

3. Matter for consideration: Provide IRS with math error authority to 
(1) use the prior year's tax return information to automatically 
verify compliance with the 2008 First-Time Homebuyer Credit payback 
provision and (2) ensure that homebuyers do not improperly claim the 
credit in multiple years; 
Date of report: September 23, 2009; 
Disposition (as of May 2011): Enacted 2009 in Public Law 111-92; 
Source: GAO-09-1026. 

4. Matter for consideration: Provide IRS with authority to use math 
error checks to identify and correct returns with ineligible (1) 
individual retirement account (IRA) "catch-up" contributions and (2) 
contributions to traditional IRAs from taxpayers over age 70½; 
Date of report: December 12, 2008; 
Disposition (as of May 2011): Not yet enacted; 
Source: GAO-09-146. 

Source: GAO. 

[End of table] 

MEA allows IRS to correct a tax return and send a notice to the 
taxpayer regarding the correction without going through the statutory 
deficiency procedures. Instead, IRS notifies the taxpayer that it has 
identified the error and has made a change to the return. Taxpayers 
have 60 days to contest the assessment outlined in those notices. 
Further, if they do not contest the assessment within that time, they 
lose their right to file an appeal with IRS or the U.S. Tax Court but 
have the option of filing an amended tax return to be considered by 
IRS. The National Taxpayer Advocate and some in Congress are concerned 
that not following the statutory deficiency procedures might undermine 
taxpayer rights because IRS might use broad authority in situations 
where it does not know with a high degree of certainty that the 
taxpayer made an error. In addition, taxpayers might not ask, within 
60 days after being assessed tax by IRS, to have their assessment 
reversed by IRS and thus might be unable to challenge an IRS notice 
through normal deficiency procedures or in the Tax Court. 

To mitigate these concerns, Congress could extend broader MEA to IRS 
but could specify criteria governing when IRS could use the authority. 
Traditionally, math error checks have allowed IRS to detect errors or 
determine taxpayer eligibility with virtual certainty, thus letting 
IRS make corrections without first corresponding with the taxpayer. To 
ensure IRS continues to use MEA only in these limited circumstances if 
given broader authority, Congress could, for example, require IRS to 
submit a report to it or an entity it designates on a proposed new use 
of MEA. The report could include how such use would meet the standards 
or criteria outlined by Congress. The report could also describe IRS's 
or the National Taxpayer Advocate's assessment of any potential effect 
on taxpayer rights. Or, Congress could require a more informal 
procedure whereby IRS simply notifies a committee, such as the Joint 
Committee on Taxation, of its proposed use and subsequently submits a 
report after such use is underway. In any case, Congress could provide 
IRS broader authority to use MEA than is currently authorized but 
still provide appropriate safeguards and require IRS to report in 
order to alleviate concerns of improper use of MEA. 

The Future Holds Significant Possibilities for Enhancing Prerefund 
Checks: 

The benefits I listed earlier of broadening MEA or using other 
prerefund compliance checks could also result from other initiatives 
that IRS has already begun or is contemplating. For example, in April, 
2011, the Commissioner of Internal Revenue talked about a long-term 
vision to increase upfront compliance activities during returns 
processing. In one example, IRS is exploring requiring that 
information returns be sent to IRS and taxpayers at the same time as 
opposed to the current requirement that some returns go to taxpayers 
before going to IRS. The intent is to move to matching those 
information returns to tax returns during tax return processing. IRS 
currently matches data provided on over 2 billion information returns 
to tax returns only after the normal filing season. Matching during 
the filing season would allow IRS to detect and correct errors before 
it sends taxpayers their refunds, thereby avoiding the costs of trying 
to recover funds from taxpayers later.[Footnote 12] This approach 
could also allow IRS to use its enforcement resources on other 
significant compliance problems. However, the Commissioner made clear 
that his vision for more prerefund compliance checks will take 
considerable time to implement. One prerequisite would be a major 
reworking of some fundamental IRS computer systems. 

Other IRS initiatives should also enhance compliance before refunds 
are issued. For instance, IRS could leverage new paid tax return 
preparer requirements to improve taxpayer compliance before tax 
returns are filed. Our work has shown that paid tax preparers play a 
vital role in administering our country's tax system and ensuring 
compliance with tax laws. Paid preparers prepare about 60 percent of 
the federal tax returns filed annually. However, we and others have 
found that some paid preparers make significant errors. We also found 
that emulating Oregon's paid preparer regulatory regime had the 
potential to lead to more accurate federal returns.[Footnote 13] In 
response, IRS is currently implementing new regulatory requirements in 
order to oversee the conduct and competency of paid preparers. 

These new requirements may improve the accuracy of tax returns 
initially prepared by paid preparers. The new requirements may also 
help IRS address compliance problems that arise during filing seasons. 
For instance, IRS may be able to identify specific paid preparers that 
are making errors and send them information on their errors, thus 
reducing errors on additional returns they may prepare during the 
filing season. To achieve the full benefits of the paid preparer 
regulatory regime, IRS must continue to make progress with its plans 
to develop a comprehensive database containing information on the 
preparers and tax returns they prepare. IRS must use information from 
this database to test which strategies are most effective for 
improving the quality of tax returns prepared by different types of 
paid preparers. To help with this effort, we recently recommended that 
IRS provide a documented framework for using the paid preparer 
requirements to improve taxpayer compliance.[Footnote 14] IRS agreed 
with this recommendation. 

Concluding Remarks: 

In closing, IRS has a massive challenge in ensuring compliance with 
the tax laws. Looking forward, with budget constraints a reality and 
burden on taxpayers a concern, doing more compliance checks before 
refunds are issued has great appeal for both taxpayers and IRS. 
Through oversight efforts like today's hearing, Congress can encourage 
and authorize the use of appropriately designed prerefund compliance 
checks that are critical to stopping erroneous refunds and ensuring 
that federal dollars are protected. 

Chairman Boustany, Ranking Member Lewis, this completes my prepared 
statement. I would be happy to respond to any questions you or other 
Members of the Subcommittee may have at this time. 

Contacts and Acknowledgments: 

For further information regarding this testimony, please contact 
Michael Brostek, Director, Strategic Issues, 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 
statement. Individuals making key contributions to this testimony 
include Joanna Stamatiades, Assistant Director; Steven J. Berke; Amy 
R. Bowser; David Fox; Tom Gilbert; Lawrence M. Korb; Inna Livits; and 
Sabrina Streagle. 

[End of section] 

Appendix I: IRS Math Error Authorities: 

Table 2 summarizes the Internal Revenue Service's (IRS) 13 areas of 
existing math error authority (MEA). As early as the first 
codification of the Internal Revenue law in 1926, Congress granted IRS 
MEA so that IRS does not have to provide taxpayers with a statutory 
notice of deficiency for math errors. A 1976 statutory revision 
defined the authority to include not only mathematical errors, but 
other obvious errors, such as omissions of data needed to substantiate 
an item on a return, and provided a statutory right to file a request 
for abatement of the assessment within 60 days after the notice is 
sent. In the 1990s, Congress extended the authority multiple times, 
and more recently it has added other provisions to help determine 
eligibility for certain tax exemptions and credits, such as the First-
Time Homebuyer Credit. 

Table 2: IRS's 13 Existing Math Error Authorities: 

Number: 1; 
Description: An error in addition, subtraction, multiplication, or 
division shown on any return. 

Number: 2; 
Description: An incorrect use of any table provided by IRS with 
respect to any return if other information in the return makes the 
incorrect use apparent. 

Number: 3; 
Description: An entry on a return of an item that is inconsistent with 
another entry of the same or different item on that return. 

Number: 4; 
Description: An omission of information that is required to be 
supplied on the return to substantiate an entry on that return. 

Number: 5; 
Description: An entry on a return of a deduction or credit in an 
amount that exceeds the statutory limit for that deduction or credit, 
if that limit is expressed as a specific monetary amount or as a 
percentage, ratio, or fraction, and if the component items of that 
limit appear on the return. 

Number: 6; 
Description: A correct taxpayer identification number (TIN) not 
provided on the return as required for the following provisions: 
* Earned Income Tax Credit (EITC); 
* child and dependent care credit; 
* personal or dependent exemption; 
* child tax credit; or; 
* Hope and Lifetime Learning credits. 

Number: 7; 
Description: A return claiming an EITC for net earnings from self-
employment, where the self employment tax imposed by I.R.C. § 1401 on 
those net earnings has not been paid. 

Number: 8; 
Description: An omission of information required for recertification 
of eligibility for the EITC. 

Number: 9; 
Description: An entry on the return of a TIN required for the EITC, 
the child credit, and the child and dependent care credit, when 
information associated with that TIN indicates that the child does not 
meet the age eligibility requirements for those credits. 

Number: 10; 
Description: An entry on the return of a claim for the EITC where the 
Federal Case Registry of Child Support Orders indicates that the 
taxpayer is the noncustodial parent of that child. 

Number: 11; 
Description: A failure to reduce Electronic Stimulus Payment credit on 
a return related to the Economic Stimulus Act of 2008 by amounts 
previously advanced. 

Number: 12; 
Description: A failure to reduce the Making Work Pay credit by the 
amount of any payment received as a result of tax abatement resulting 
from the combat-related deaths of members of the Armed Forces, deaths 
of astronauts, and deaths of victims of certain terrorist attacks, or 
by the amount of any credit allowed under the American Recovery and 
Reinvestment Act of 2009, or a failure to submit a proper Social 
Security number with the claim. 

Number: 13; 
Description: A claim for the First-Time Homebuyer Credit where the 
taxpayer has not included the required settlement statement; 
or where other information indicates that the taxpayer is under 18 
years of age, or where information from the past 2 years of returns 
indicates ineligibility for the credit. Additionally, IRS may correct 
the return where the taxpayer has failed to include the increased tax 
required under the recapture provision for the credit, when applicable. 

Source: GAO analysis. 

[End of table] 

[End of section] 

Footnotes: 

[1] IRS is granted math error authority in 26 U.S.C. § 6213 (b). It 
can be used for certain purposes specified by Congress in 26 U.S.C § 
6213 (g)(2) including correcting calculation errors and checking for 
other obvious noncompliance such as claims above income and credit 
limits. If it is not specified in statute, IRS cannot pursue 
assessment and collection activities without issuing a statutory 
notice of deficiency. 

[2] See GAO, Financial Audit: Examination of IRS' Fiscal Year 1997 
Custodial Financial Statements, [hyperlink, 
http://www.gao.gov/products/GAO/AIMD-98-77] (Washington, D.C.: Feb. 
26, 1998). 

[3] GAO, 2011 Tax Filing: IRS Dealt with Challenges to Date but Needs 
Additional Authority to Verify Compliance, [hyperlink, 
http://www.gao.gov/products/GAO-11-481] (Washington, D.C.: Mar. 29, 
2011). 

[4] Tax fraud is defined as the willful attempt to defeat or 
circumvent the tax law in order to illegally reduce one's tax 
liability. 

[5] Identity theft becomes a problem for taxpayers and IRS through 
refund fraud. The name and Social Security number used by identity 
thieves can be stolen from numerous sources outside of IRS's control. 
See GAO, Tax Administration: IRS Has Implemented Initiatives to 
Prevent, Detect, and Resolve Identity Theft-Related Problems, but 
Needs to Assess Their Effectiveness, [hyperlink, 
http://www.gao.gov/products/GAO-09-882] (Washington, D.C.: Sept. 8, 
2009). 

[6] The Housing and Economic Recovery Act of 2008 established a 
refundable FTHBC, repayable over 15 years with a $7,500 limit. Pub. L. 
No. 110-289, § 3011, 122 Stat. 2654 (July 30, 2008). The American 
Recovery and Reinvestment Act of 2009 amended the credit to waive the 
repayment requirement and raised the maximum to $8,000. Pub. L. No. 
111-5, div. B, tit. I, § 1006, 123 Stat. 115 (Feb. 17, 2009). The 
Worker, Homeownership, and Business Assistance Act of 2009 extended 
the time frame to claim the credit and allowed claims by certain long-
term homeowners purchasing new homes. Pub. L. No. 111-92, § 11, 123 
Stat. 2984 (Nov. 6, 2009). 

[7] Congress provided IRS authority to check the previous year's tax 
returns when it extended the credit for the final time in November 
2009. Pub. L. No. 111-92, § 12(d). 

[8] GAO, Tax Administration: IRS's 2008 Filing Season Generally 
Successful Despite Challenges, although IRS Could Expand Enforcement 
during Returns Processing, [hyperlink, 
http://www.gao.gov/products/GAO-09-146] (Washington, D.C.: Dec. 12, 
2008). 

[9] The refundable Making Work Pay tax credit provided up to $400 for 
working individuals and up to $800 for married taxpayers filing joint 
returns for 2009 and 2010. Pub. L. No. 111-5, div. B., tit. I § 1001, 
123 Stat. 115, 309 (2009). See GAO, 2010 Tax Filing Season: IRS's 
Performance Improved in Some Key Areas, but Efficiency Gains Are 
Possible in Others, [hyperlink, 
http://www.gao.gov/products/GAO-11-111] (Washington, D.C.: Dec. 16, 
2010). 

[10] GAO, Recovery Act: IRS Quickly Implemented Tax Provisions, but 
Reporting and Enforcement Improvements Are Needed, [hyperlink, 
http://www.gao.gov/products/GAO-10-349] (Washington, D.C.: Feb. 10, 
2010). 

[11] [hyperlink, http://www.gao.gov/products/GAO-11-481]. 

[12] GAO, Taxpayer Account Strategy: IRS Should Finish Defining 
Benefits and Improve Cost Estimates, [hyperlink, 
http://www.gao.gov/products/GAO-11-168] (Washington, D.C.: Mar. 24, 
2011). 

[13] GAO, Tax Preparers: Oregon's Regulatory Regime May Lead to 
Federal Tax Return Accuracy and Provides a Possible Model for National 
Regulation, [hyperlink, http://www.gao.gov/products/GAO-08-781] 
(Washington, D.C.: Aug. 15, 2008). 

[14] GAO, Tax Preparer Regulation: IRS Needs a Documented Framework to 
Achieve Goal of Improving Taxpayer Compliance, [hyperlink, 
http://www.gao.gov/products/GAO-11-336] (Washington, D.C.: Mar. 31, 
2011). 

[End of section] 

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