Recommendations for Executive Action

1. Status: Closed - Implemented

   Comments: Through an IRS Request for Information Services (GOE4-0050A00), the IRS plans to (1) develop an automated process to compare the taxpayer identification number (TIN) of federal agencies that file Form 1099 MISC annual information returns with federal agency TINs recorded in the IRS's Business Master File, (2) identify federal agency TINs for which no annual information returns were filed, and (3) contact the agencies via notice to determine whether they have a filing requirement. Status as of September 2007: In October 2005, the Central Contractor Registration system began requiring potential federal contractors to provide a TIN that can be matched against IRS records. As of August 2007, there were 526 notices sent out to federal agencies for inaccurate contractor Form 1099 TINs for TY 2005. This shows little improvement over a similar mailing 2 years earlier. According to the IRS official responsible for the federal contractor TIN matching program, by Summer 2008 there should be a noticeable improvement in Form 1099 TIN accuracy since effect of the improved contractor registration requirements had not fully taken effect by the end of Calendar Year 2005. IRS has taken actions consistent with our recommendation to ensure the accuracy of TINs from federal agencies, although accuracy has not yet demonstratively improved. As such, we are closing this recommendation as implemented.

   Recommendation: To ensure that federal agencies file Forms 1099 MISC for payments to vendors for services provided, the Commissioner of Internal Revenue should ensure the accuracy of identification information concerning federal payers in IRS's Payer Master File.

   Agency Affected: Department of the Treasury: Internal Revenue Service

2. Status: Closed - Implemented

   Comments: Through an IRS Request for Information Services (GOE4-0050A00), the IRS plans to (1) develop an automated process to compare the taxpayer identification number (TIN) of federal agencies that file Form 1099 MISC annual information returns with federal agency TINs recorded in the IRS's Business Master File, (2) identify federal agency TINs for which no annual information returns were filed, and (3) contact the agencies via notice to determine whether they have a filing requirement. Status as of September 2007: In August 2007 for Tax Year 2005, IRS sent out 62 form 1313 notices to federal agencies which are not filing information returns. This shows no improvement from a similar mailing sent in August 2005. The IRS official responsible for this program stated that in the past year, IRS has initiated an employment tax compliance program for federal agencies which includes independent contractor and form 1099-MISC compliance.

   Recommendation: To ensure that federal agencies file Forms 1099 MISC for payments to vendors for services provided, the Commissioner of Internal Revenue should develop a program to periodically identify federal agencies that fail to file Forms 1099 MISC and follow up to determine why the forms were not filed.

   Agency Affected: Department of the Treasury: Internal Revenue Service

3. Status: Closed - Implemented

   Comments: In response to the recommendation, OMB agreed to develop and issue a directive requiring validation of taxpayer identification numbers (TIN) using either the central contractor registration (CCR) or IRS's TIN verification program. September 2007: See accomplishment report GAO-07-1837A.

   Recommendation: To minimize duplicate agency effort in validating vendors' TINs and to reinforce the anticipated role of the Central Contractor Registration as the single validated source of vendors doing business with the federal government, the Commissioner of Internal Revenue and the Director of the Office of Management and Budget should consider options to routinely validate all vendor TINs in the CCR and to then require all agencies to use vendor and TIN information from the CCR for their Forms 1099 MISC. If this proves to be infeasible, OMB should require each agency to validate TINs for vendors who provide services through IRS's TIN-matching program.

   Agency Affected: Executive Office of the President: Office of Management and Budget

4. Status: Closed - Implemented

   Comments: As of October 30, 2005, to qualify as a registrant to bid for all federal government contracts or apply for federal assistant awards, the registrant must have a Taxpayer Identification Number(TIN) that can be validated by the Internal Revenue Service. The TIN and the registrant's name provided to GSA's Central Contractor Registration (CCR) system must match exactly to the TIN and Taxpayer Name used in federal tax matters. Since November 2005, IRS has reviewed the TIN and name validity of over 770,000 CCR registrants. About 19 percent or over 147,000 potential registrants did not pass the TIN validation process and were not allowed to register on CCR system.

   Recommendation: To minimize duplicate agency effort in validating vendors' TINs and to reinforce the anticipated role of the Central Contractor Registration as the single validated source of vendors doing business with the federal government, the Commissioner of Internal Revenue and the Director of the Office of Management and Budget should consider options to routinely validate all vendor TINs in the CCR and to then require all agencies to use vendor and TIN information from the CCR for their Forms 1099 MISC. If this proves to be infeasible, OMB should require each agency to validate TINs for vendors who provide services through IRS's TIN-matching program.

   Agency Affected: Department of the Treasury: Internal Revenue Service

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