# IRS Working Paper, January 10, 2025, Not for quotation or citation.

> Briefs, arguments, decisions, and more.

URL: https://www.frixlaw.com/law-library/documents/agency%3Airs%3A7ada4e404fd4f6f2

## Record

- **Collection:** Agency decision
- **Document type:** Agency decision

## Text

IRS Working Paper, January 10, 2025, Not for quotation or citation.

More Than Meets the Eye:
The Comprehensive General Indirect Effect of Auditing Individual
Income Tax Returns ∗
Alan Plumley and Daniel Rodriguez
IRS Research, Applied Analytics, and Statistics

Jess Grana and Miguel Sarzosa
MITRE

The views expressed in this paper are those of the authors and do not necessarily represent the
views of the IRS or of MITRE.
January 10, 2025
Abstract
IRS audit rates have generally fallen for over a decade due to declining resources.
In addition to loss of direct revenue, decreased enforcement likely results in
increased noncompliance, as well. We contribute to a small literature on the
“comprehensive” indirect effects of IRS enforcement on voluntary compliance
across the general taxpayer population—mostly those who were not directly subject
to the enforcement. Using microdata from random audits conducted for research
purposes, we find that misreporting increases on certain tax return line items as
overall audit rates decline. As we might expect, these effects are more pronounced
for line items that are the typical target of audits rather than line items addressed
through the automated matching program. We translate effects on misreporting into
effects on tax revenues and compare revenues against enforcement costs. We find
that over the Tax Year 2006-2014 period, the overall average marginal return on
investment (ROI) of IRS individual tax enforcement was between 13:1 and 16:1,
including a direct average ROI of 3:1 and an indirect average marginal ROI
between 10:1 and 13:1. In other words, for this time period, the general indirect
effect was 3 to 4 times the direct revenue effect. These ROI estimates advance
current understanding of the IRS’s overall impact and can inform budgetary
discussions.
Keywords: Tax audits, Spillovers, General Indirect Effect, ROI of audits
JEL Codes: H23, H26

The authors would like to thank Will Boning and comments from participants at the IRS-Tax Policy Center Joint
Research Conference on Tax Administration (June 2023), the National Tax Association annual conference (Nov 2023),
the Georgetown Tax Law and Public Finance Workshop (Jan 2024), the Society of Government Economists annual
conference (April 2024), the IRS Research, Applied Analytics, and Statistics peer review (Oct 2024), the Department
of the Treasury Office of Tax Analysis and IRS Joint Statistical Research Program seminar (Oct 2024), and the
Government Accountability Office (December 2024). Alan Plumley email: alan.plumley@irs.gov. Daniel Rodriguez
email: daniel.rodriguez@irs.gov. Jess Grana email: cheny@mitre.org. Miguel Sarzosa email: msarzosa@mitre.org.
∗

IRS Working Paper, January 10, 2025, Not for quotation or citation.

1 Introduction
How much additional revenue could be generated if the enforcement budget for the Internal
Revenue Service (IRS) were increased by $X per year? The answer to that question is far from
simple; it depends on the size of the current budget and how it is allocated to enforcement,
services, IT investments, and other activities. It also depends on how the enforcement budget is
allocated to the various enforcement programs. One impact on overall revenue would come in
the form of increased direct enforcement revenue – additional tax collections resulting from the
enforcement action for the tax year being enforced. Moreover, it is likely that the direct effect
would be accompanied by some indirect revenue effects—whether due to a subsequent change in
compliance behavior among the specific taxpayers who were the subjects of the enforcement
(known as the “specific indirect effect”), and/or a spillover due to a change in compliance
behavior among taxpayers in the general population who were not the subjects of the
enforcement (known as the “general indirect effect”). Estimating the spillovers of enforcement,
and thus the full extent of the return to investing in tax enforcement, is not straightforward, but it
is extremely important. The IRS 2024 budget request to Congress is a testament to this. It cites a
return on investment (ROI) in terms of direct revenue but “does not include the indirect effects of
IRS enforcement activities on voluntary compliance” (IRS, 2024). This paper intends to fill this
gap.
There have been numerous attempts over the last 40 years to estimate the general indirect effect
of changes in IRS enforcement—particularly changes in audit coverage rates. These efforts fall
within two approaches: (1) “local network” models; and (2) “comprehensive” models. Local
network models attempt to demonstrate that a general indirect effect exists in a particular
context. For example, they estimate the general indirect effect within a given segment of the
population (e.g., sole proprietors) through a specific type of network (such as the network of
taxpayers who are clients of the same tax preparer) and according to a particular behavioral
mechanism (e.g., deterrence). Using well-defined networks supports strong identification
strategies whereby a treatment group (i.e., a network that had an audited member) is compared
against a similar but untreated group. A drawback of local network models is that they are
context-specific. 1 Their findings may not be generalizable outside of the specific context or
behavioral mechanism studied. Taxpayers presumably participate in multiple networks
simultaneously (e.g., employer networks, professional networks, community networks, etc.), and
it is unclear whether the separate impact of these networks are additive. Taxpayers undoubtedly
form their perceptions in a more subtle way based on all the factors in their environment.
Although local network models lend themselves to theoretical premises and practical
experimentation, such narrowly defined analyses do not directly translate into operational
applications such as budget justification. To achieve that, the estimated indirect effects should in
theory include effects arising: 1) from all IRS enforcement activities; 2) across the general
taxpayer population; and 3) across all possible (or as many as possible) networks of propagation.
Comprehensive models are better suited for these purposes as they are agnostic about the
For instance, studies like Boning et al. (2020), Badgley et al. (2021), and Chetty (2013) show large spillovers of
audits that spread through networks of different kinds. Others that explore more light-touch interventions like
mailing letters shaming delinquent tax filers find mixed or no evidence of an indirect effect (Meiselman (2018);
Perez-Truglia and Troiano (2018); Grana et al. (2022)). These mixed results indicate that context matters: the
existence and size of an indirect effect depend on the specific network or community studied or even on research
design choices.

1

IRS Working Paper, January 10, 2025, Not for quotation or citation.
mechanism(s) affecting taxpayer behavior and are generally not restricted to a narrow subset of
the population. However, their identification is less straightforward. They depend heavily on
being able to control for all the main drivers of behavior in addition to the enforcement activity
in question.
This paper estimates a comprehensive model of the impact of individual income tax audits on the
general population. It is motivated by the observation that, due to a steady decline in IRS budgets
over the last 12 or so years, overall individual income tax audit coverage rates (the percentages
of any given subpopulations that are audited) have declined substantially, going from 1% in 2008
to less than 0.6% in 2014 (see Figure 3 in the Appendix). Despite the overall decline, audit rates
did not fall uniformly across Examination Activity Codes—IRS’ groupings of taxpayers based on
Total Positive Income 2 (TPI) level, the filing of certain schedules, and the claiming of the Earned
Income Tax Credit (EITC). 3 For instance, while audit rates fell from 10.8% in 2008 to 2.6% in
2014 for those earning $1,000,000 or more (Activity Code 281), Figure 1 shows that audit rates
in other Activity Codes remained somewhat stable and, in some instances, they even increased at
various points in time.
Figure 1. Audit Rates by Activity Code

Descriptive evidence suggests the existence of co-movement between audit rates and
noncompliance—measured by the Net Misreporting Percentage (NMP) on tax after refundable
credits (TARC). 4 As an example, Figure 2 illustrates the audit coverage and misreporting rates
TPI is the sum of all positive amounts of income and excludes income losses, such as from investments.
See the lists of Activity Codes, their definitions, and their relative importance as percentage of the taxpayer
population in Table 7 of the Appendix.
4
The NMP is defined as the aggregate net amount misreported on a given line item across a group of returns divided
by the sum of the absolute values of the corresponding amounts that should have been reported. The absolute values
are used in the denominator to ensure that negative amounts do not distort the aggregates. These misreporting
statistics were compiled from data generated by audits of a stratified random sample of tax returns each year under
the IRS National Research Program (NRP).
2
3

IRS Working Paper, January 10, 2025, Not for quotation or citation.
for individuals in Activity Code 272 (i.e., those whose returns fall below $200,000 in TPI and
which are not accompanied by supplemental forms like Schedule C, E, F or Form 2106 5 and do
not claim the EITC). This group comprises over half of all individual tax returns. Figure 2 shows
an overall upward trend in noncompliance contemporaneous with a declining trend in the audit
coverage rates over these years, suggesting the presence of a general indirect effect among this
large group of taxpayers.
Figure 2. Audit Coverage and NMP Trends, TYs 2006-2014 for Taxpayers with TPI <$200k
and no EITC, Schedule C, E, F or Form 2106 (55.3% of the Population)

In addition to an overall compliance response to changes in audit coverage, we further
hypothesize that this effect varies by the visibility of income and other tax return line items.
Compliance is more likely to be affected on line items that are often targets of audits. Line items
subject to automated matching programs (which are not audits) may be less affected by changing
audit rates.
This paper adds to the literature on the indirect effect of audits by using alternative model
specifications and exploiting new individual microdata to capture noncompliance. We differ from
prior research in our econometric specification: instead of the contemporaneous audit rate, we
evaluate the effect of a lagged audit rate on compliance. Taxpayers do not have contemporaneous
knowledge of the audit rate since information disseminates with a lag. Moreover, the IRS’s
estimate of the risk that a given return is noncompliant is also not contemporaneous; it is based
on audit results of similar returns from prior years. The significance of these lags is that they
reduce endogeneity concerns arising from reverse causality. We also differ from prior work by
Schedules C and F are used to report nonfarm and farm sole proprietor income and expenses, respectively;
Schedule E is used to report income from rental real estate, royalties, partnerships, S corporations, estates, trusts, or
residual interests in real estate mortgage investment conduits; and Form 2106 is used to report employee business
expenses.
5

IRS Working Paper, January 10, 2025, Not for quotation or citation.
exploring how the compliance response differs across groups of line items based on how visible
the line item is to the IRS through third-party reporting.
Our findings largely confirm the hypothesis that individual misreporting responds to audit rate
changes differently across visibility groups of line items in ways consistent with the extent of the
visibility. We translate the impact of audit rates on the misreporting of income or offset amounts
to the impact on tax revenues. Then, comparing revenues against enforcement costs, we calculate
the overall return on investment (ROI) of audits of individual income tax returns. We find that,
on average, $1 spent on individual income tax audits generates about $3 of direct revenue and an
additional $10 to $13 of indirect revenue (roughly 3 to 4 times the direct revenue). Our findings
are within the range of magnitude estimated by a handful of prior studies and close to the
estimate put forward by the U.S. Treasury indicating that the indirect effect is three times the
direct effect (Department of the Treasury, 2019).
The paper is organized as follows: Section 2 reviews the relevant empirical literature and
provides theoretical motivation for this research; Section 3 describes our data; Section 4
summarizes our estimation methods; Section 5 presents our empirical results; and Section 6
concludes.

2 Background and Theoretical Motivation
The decision to declare taxes is made under uncertainty. That is because a taxpayer’s failure to
fully report their income does not automatically trigger punishment from tax authorities. If a
taxpayer underreports income, the reward of doing so will depend on whether or not they are
investigated by the authorities. If they are not investigated, they are better off underreporting
than declaring their full income. However, if they are investigated and the penalty for
underreporting is greater than its benefits, they are worse off. That is why in the classical
economic theory of tax compliance, rational (risk-averse) individuals maximize the expected
utility of the tax evasion gamble, purposefully comparing the expected monetary benefits of
gaming the tax system against the risky prospect of detection and punishment (Allingham and
Sandmo, 1972). A key parameter in this context is, of course, the probability of detection. A
well-established result in the classical economic theory of tax compliance is that an increase in
the probability of detection will always lead to more income being declared (Lopez-Luzuriaga
and Scartascini, 2019). That is because a higher probability of detection reduces the expected
payoff of underreporting.
Incidentally, this is the theoretical foundation for the existence of the general indirect effect of
audits that we explore in this paper—the effect of IRS contacts (such as audits) on those who are
mostly not contacted themselves. It is not the fact that the person is audited, but the chances of
someone getting audited that drive the change in tax reporting. Early empirical evidence supports
this result. Studies like Dubin and Wilde (1988), Dubin, Graetz and Wilde (1990), Tauchen,
Witte and Beron (1993), and Plumley (1996), which we refer to as measuring the
“comprehensive indirect effect”, find that higher aggregate (e.g., state or ZIP code level)
contemporaneous audit rates on the general population (as a proxy for audit probability) are
associated with greater tax compliance. For example, using state-level panel data, Dubin, Graetz
and Wilde (1990), Plumley (1996), and Dubin (2007) find that the comprehensive indirect effect
of audits is six, eleven, and nine times that of the direct effect, respectively. Dubin and Wilde

IRS Working Paper, January 10, 2025, Not for quotation or citation.
(1988) and Grana et al. (2022) use zip-code level panel data and find mixed evidence of an
indirect effect, varying across taxpayer subpopulations and audit categories (see Table 1).
Table 1: Findings from Prior Studies on the Comprehensive General Indirect Effect
Ratio of Indirect to Direct Revenue (not ROI)
2:1 (high-income taxpayers only)
Tauchen, Witte, and Beron (1993)
6:1
Dubin, Graetz and Wilde (1990)
9:1
Dubin (2007)
11:1
Plumley (1996)
Mixed evidence
Dubin and Wilde (1988) and Grana et al. (2022)
However, contemporaneous audit rates are not public knowledge. So, if national audit rates are
abstract or distant from the day-to-day concerns of individual taxpayers, how can they have a
significant impact on tax reporting behavior? Taxpayers must build perceptions about them from
partial information gathered through various channels. The analyses of some of those channels
build a complementary and larger body of knowledge within the general indirect effects
literature. This sub-strain of the literature incorporates “local network” models that focus on a
single context and channel of information transmission.
One of those channels is tax preparers. Professional tax preparers closely monitor national audit
rates to better advise their clients. If audit rates are high, tax preparers may be more diligent in
ensuring compliance and advising clients to avoid aggressive tax positions. This professional
guidance influences taxpayers' behavior, even if they are not directly aware of the audit statistics
(Keppler, Mazur and Nagin, 1991). Boning et al. (2020) and Badgley et al. (2021) show that
professional tax preparers also catalyze a network effect on tax reporting. They find that
taxpayers who share tax preparers with IRS-visited/audited taxpayers tend to report more income
to the tax authorities. 6 That may be because the tax preparer becomes aware firsthand of the
possibility of misreporting detection and transfers that information to their other clients who
update their perceptions about the detection probability they face.
A similar channel through which aggregate audit rates can inform individual’s perceptions on
their chances of detection, akin to that of tax preparers, comprises taxpayers’ social networks. As
with tax preparers, this channel relies on making the taxpayer aware that she could have been
audited (or not) as their peers, family members, or colleagues have (or have not) been. This
channel’s effects capture responses driven by information about enforcement spread through the
network by word of mouth. As shown by Chetty et al. (2013) when documenting the geographic
variation in the take-up of the EITC, the knowledge generated by word of mouth can lead to
significant heterogeneity in behavior adoption. This mechanism is made explicit by Alstadsæter
et al. (2019) and Drago et al. (2020), who document that taxpayers affect each other’s decisions
about tax avoidance. In particular, Drago et al. (2020) find that neighbors of those who received
a letter addressing their tax reporting are more likely to switch from evasion to compliance than
households living in neighborhoods where no one received such a letter. These findings highlight
the fact that individuals form beliefs about their own detection probability using even fragmented
Similarly on the corporate taxation side, Bohne and Nimczik (2018) find that tax avoidance behaviors follow
managers and tax experts as they transfer between firms. Pomeranz (2015) finds that after a firm is audited, tax
compliance also improves among that firm’s suppliers.

6

IRS Working Paper, January 10, 2025, Not for quotation or citation.
information about aggregate audit rates, such as observing a neighbor receiving a tax-related
letter, profoundly shaping personal perceptions of audit risk. This suggests that individuals
extrapolate from these isolated instances to infer broader enforcement patterns, thus integrating
these observations into their understanding of the likelihood of being audited themselves, which
in turn influences their tax compliance decisions.
A similar reasoning can be used to understand how media coverage of specific audits and audit
rates can inform a person’s perception of audit risk, especially if those audits occur to people
with similar characteristics to them. One of those characteristics can be the location where the
audited people live. Tauchen, Witte, and Beron (1993) use audit rate variation at IRS-office level
on microdata from the IRS Taxpayer Compliance Measurement Program (TCMP) 7 to find that
local audit rates stimulate individual compliance. 8 They estimate that the indirect effect of audits
is twice the size of the direct effect. The reasoning for using office-level audit rates stems from
the fact that back in the 1970s, the period the paper analyzes, IRS district offices conducted the
audits and had different staffing levels. Thus, the number of audits they could complete varied
across district offices. As a result, some taxpayers were audited or not audited because they filed
in districts that were over- or under-staffed in relation to other districts. Therefore, the local audit
rate was informative to local taxpayers building their belief about the detection probability they
would face. As the IRS budget shrank over time and catalyzed by IRS restructuring in 1998,
auditing responsibility shifted from district offices to a centralized system heavily reliant on
correspondence audits. Hence, since the 2000s taxpayers’ audit rate references are largely
national instead of local.

3 Data
Our methodology relies on modeling individual level compliance as a function of IRS audit
rates, while controlling for other drivers of compliance. Our primary compliance measure is
derived from National Research Program (NRP) microdata. NRP selects a stratified random
sample of individual income tax returns for examination for a given tax year. Because the NRP
sample is designed to be representative of the population, audits through the NRP examine
taxpayers who might not have been examined under normal operational audit procedures. These
audits potentially encompass the whole tax return, as opposed to targeting specific areas of
noncompliance, as in operational audits. The program provides useful information about
noncompliance among the general population and the insights it reveals are used to update
operational audit selection procedures, improve resource allocation, and provide estimates of the
tax gap (IRS, 2022).
We interpret the behavior of the individuals in the NRP sample as being representative of similar
taxpayers in the general population. However, we are interested in the aggregate audit rate faced
by the segment of the population represented by the NRP taxpayer—not the audit probability of

TCMP, a precursor to IRS’s NRP, contained detailed information on compliance (resulting from detailed audits) for
a stratified random sample from the population.
8
On the corporate side, Hoopes, Mescall and Pitman (2012) take a similar approach and find that doubling the audit
rate increases effective tax rates by 7 percent. Notably, they survey corporate tax executives and find that many take
note of historical audit rates.
7

IRS Working Paper, January 10, 2025, Not for quotation or citation.
the taxpayer in the NRP sample. Audit rates are constructed by aggregating IRS enforcement
data according to the audit categories employed by both NRP and operational audits.

3.1 Dependent Variables
We select all returns audited through the NRP for TYs 2006-2014. 9 For each return, we use the
reported amounts and NRP-corrected amounts of certain line items. Our primary outcome
variable is the net misreported amount (NMA), a concept used throughout tax gap studies (IRS,
2022). It is calculated for a given set of line items as the difference between the correct amounts
and reported amounts for each return. We calculate six measures of NMA based on categories of
line items at the return level that span different types of income and offsets. For income and tax
categories, NMA is calculated as Corrected Amount – Reported Amount, and positive NMA
values indicate understatements of tax. For offset categories (e.g., offsets to income, such as
deductions, and offsets to tax, such as credits), NMA is calculated as Reported Amount –
Corrected Amount, so that positive NMA values again indicate understatements of tax.
For each return, we compute the NMA for six groups of tax return line items based on how
visible they are to the IRS. Four of the line-item groups relate to different types of income
(Visibility Groups 1-4), while the remaining two groups combine offsets to income (Visibility
Group 5) or offsets to tax (Visibility Group 6). We define visibility as the degree to which
income or offsets are subject to withholding and/or third-party information reporting.
Compliance on income reporting varies with the “visibility” of the income. Income subject to
little or no information, such as sole proprietor income, makes up the largest portion of the
underreporting tax gap (IRS, 2022).
Figure 3: Underreporting of Income as a Function of its Visibility to the IRS

Source: Internal Revenue Service (2022)
2015 NRP data was released at the time of the writing of this report, and we are adding these data to our sample in
ongoing work.

9

IRS Working Paper, January 10, 2025, Not for quotation or citation.

Visibility Group 1 is the income category subject to the most information reporting and
withholding while Visibility Group 4 is subject to the least. We hypothesize that compliance on
certain line items may be more responsive to IRS audit rates than others. For example, rising
audit rates may induce taxpayers to more accurately report line items that would be typically
targeted by an audit – items that have substantial, limited or even low visibility. It is unclear
whether taxpayers change their compliance behavior on high visibility line items that are usually
handled by automated document matching programs rather than by audits. It is also unclear
whether taxpayers change compliance on items with no information reporting since such income
can be difficult to validate through audits. In our analysis, we evaluate each NMA measure as the
dependent variable in separate analyses.
Each of the six NMA measures are relevant only to certain taxpayers, depending on their tax
situation. For each visibility group regression, we remove taxpayers who report zero amount and
have zero true (corrected) amount on any of the line items in the visibility group. This ensures
that a zero NMA value corresponds to compliance behavior and not to irrelevance of line items
for the given taxpayer.
Table 2. Visibility Group Definitions
Visibility
Group
1

Category

Line Items Included

Income

Wages & Salaries

2

Income

3

Income

4

Income

Pensions and annuities, unemployment compensation,
dividend income, interest income, state income tax
refunds, and taxable social security
Partnerships/S corp. income, capital gains, and
alimony income
Nonfarm proprietor income, other income, rents and
royalties, farm income, and form 4797 income

5

Offsets to
income
Offsets to
tax

6

Adjustments, deductions, and exemptions
Refundable and nonrefundable credits

Visibility
High: subject to substantial
information reporting and
withholding
Substantial: subject to substantial
information reporting
Limited: subject to some
information reporting
Low: subject to little or no
information reporting
Mixed: subject to varying
amounts of information reporting
Mixed: subject to varying
amounts of information reporting

3.2 Independent Variables
3.2.1 Audit Rates
The primary regressors of interest are audit rates. We construct the audit rate for a given tax year
from IRS enforcement data as the number of unique tax returns from that tax year that were
audited divided by the total number of unique returns filed for that year. We also create separate
audit rates for different groupings of taxpayers based on TPI level, the filing of certain schedules
(like Schedule C for nonfarm sole proprietors and Schedule F for farm sole proprietors) and
EITC claiming. These groupings of individual tax returns – known as “activity codes” – are
listed in Table 7 of the Appendix. As the third column of Table 7 shows, most of the taxpayer
population has modest annual income (below $200,000) and no active business income or
expenses (Activity Codes 272 and 273).

IRS Working Paper, January 10, 2025, Not for quotation or citation.
It is important to note that our dependent variable and other control variables are specified at the
return level, but our primary variable of interest – audit rates – is specified at the group level.
Each observation in our NRP sample is assigned the audit rate for that return’s activity code –
reflecting the likelihood that taxpayers are most responsive to audits of similarly situated
taxpayers (e.g., with similar types and amounts of income and offsets).
The second methodological decision we made about the audit rate variable was to specify a twoyear lag of audit rate in the regressions. The choice to lag the audit rate arises from the natural
delay in enforcement processing time. Figure 4 provides an example of the distribution of audit
start and audit closure dates relative to the filing year of the audited return, for two categories of
audit. For many audit categories, an audit begins 2-3 years and closes 2-4 years after the filing
year of the audited return. For example, a return for income earned in TY2010 would be filed in
spring 2011. If selected for audit, the taxpayer might be notified in late 2012. In spring 2013, the
taxpayer will file the TY2012 return. Thus, the audit rate pertaining to TY2010 returns is the
most recent information the taxpayer will have on IRS enforcement levels when filing the
TY2012 return – motivating a two-year lag on audit rate in our regressions.
Figure 4: Distribution of Audit Start and Closure for Two Categories of Audit

3.2.2

Control Variables

For each NRP return, our control variables are constructed from tax characteristics that may help
explain compliance behavior. These include filing status (whether the taxpayer filed as Married
Filing Jointly), the total exemptions claimed by the taxpayer, the presence of wage income, the
claiming of the child tax credit, whether the taxpayer itemized deductions, whether mortgage
interest was deducted, an indicator for taxpayers over 65 years of age, whether the taxpayer used
a paid preparer, and an indicator for electronic filing. We base these variables on the taxpayer’s
reported information on their return.
We also control for the correct amount on the return corresponding to the NMA variable of
interest. For example, when Visibility Group 6 (credits) NMA is the dependent variable, we
include the correct amount of credits as the regressor. This construction allows us to model
changes in NMA that arise from compliance behavior and not from changes in the underlying
true tax, income, or offsets.

IRS Working Paper, January 10, 2025, Not for quotation or citation.

3.3 Data Summary
Figure 5 summarizes sample size by activity code. We remove outliers by trimming the bottom
and top five percent from the distribution of total reported income in each activity code, since
there are outliers in terms of high income and negative income. This trimming affects the entire
NRP sample, regardless of visibility group. Within each visibility group regression, we remove
observations with negative NMAs. Negative NMAs imply overstating of income or
underclaiming of offsets, and in this paper, we focus on focus on noncompliance in the other
direction (which is more common). Except for Activity Code 271, our sample includes at least
4,000 returns for each activity code during TYs 2006-2014.
Figure 5. Counts of NRP Returns Before and After Trimming (TYs 2006-2014)

Figure 7 summarizes the aggregate NMA over time by visibility group. The total NMA for each
visibility group is calculated by weighting each return-level NMA in our NRP sample (using
NRP sampling weights) and summing across all returns. The largest source of noncompliance is
from Visibility Group 4, income line items with little or no information reporting (such as
nonfarm proprietor income and rents and royalties income). Aggregate NMA in this group fell
and then increased over time. The totals for Visibility Groups 3 and 5 fell and plateaued
somewhat.

IRS Working Paper, January 10, 2025, Not for quotation or citation.
Figure 7. Aggregate NMA* over Time, by Visibility Group (Weighted)

* The NMA for groups 1-4 represent understated income, while the NMA for group 5 represents overstatements of
income offsets and the NMA for group 6 represents overstatements of tax credits.

Figure 8 disaggregates NMA totals by activity code. Certain types of taxpayers are more likely to
have certain types of income and offsets and are thus more likely to contribute to NMA on those
items. For example, Activity Code 270 makes up a large portion of misreporting on credits
(Visibility Group 6) but a much smaller portion of misreporting on partnership/S corporation
income, capital gains and alimony income (Visibility Group 3). Activity Codes 279-281, despite
comprising only 3.7 percent of the population (per Table 7), contribute almost 25 percent of
misreporting on Visibility Group 3 income. Activity Code 272, which includes over 55 percent of
the population, contributes the largest portion of misreporting in Visibility Groups 1 and 2 but
much less for 3 and 4.
Figure 8. Aggregate NMA by Activity Code (Weighted)

Table 3 summarizes the dependent and independent variables in our model (excluding audit
rates) by Tax Year. These summary statistics apply to our trimmed data, and observations are

IRS Working Paper, January 10, 2025, Not for quotation or citation.
weighted by NRP sampling weights. Dollar-denominated variables (NMAs and Correct
Amounts) are adjusted to 2018 dollars. For the average return in our sample, NMA drops slightly
then increases during this time for most visibility groups. Correct amounts of Visibility Group 1,
3 and 4 income also drop slightly then increase during this time. Commensurate with decreasing
marriage rates and our aging population, the proportion of NRP taxpayers filing as Single/other
status increases somewhat, as does the proportion of taxpayers over 65. Variables declining
during this time are the proportion of taxpayers with wage income, claiming a child tax credit,
itemizing, and deducting mortgage interest. The use of a paid preparer fell over time, while
electronic filing rose dramatically until 2012 then slightly declined.

IRS Working Paper, January 10, 2025, Not for quotation or citation.
Table 3. Weighted Average Statistics for NRP Sample by Tax Year
Variable
2006
2007
2008
2009
2010
2011
2012
2013
2014
Dependent Variable (NMA)
Visibility Group 1
$157
$175
$189
$107
$140
$78
$144
$57
$143
Visibility Group 2
$416
$363
$347
$478
$462
$300
$395
$387
$416
Visibility Group 3
$1,194
$1,283
$695
$688
$663
$600
$723
$717
$938
Visibility Group 4
$3,617
$3,048
$2,762
$2,544
$2,720
$2,379
$2,827
$3,247
$3,156
Visibility Group 5
$893
$1,561
$1,370
$1,367
$1,395
$1,404
$1,225
$1,250
$1,443
Visibility Group 6
$330
$355
$369
$487
$545
$552
$451
$457
$447
Independent Variables
Correct Amount
Visibility Group 1
$52,400
$52,745
$50,424
$49,944
$48,948
$47,822
$50,503
$49,492
$50,665
Visibility Group 2
$9,715
$10,367
$9,745
$9,836
$10,191
$9,972
$9,728
$9,697
$10,141
Visibility Group 3
$10,290
$10,028
$6,477
$5,009
$6,135
$6,507
$8,382
$8,008
$9,623
Visibility Group 4
$11,556
$10,538
$9,613
$8,680
$9,770
$9,467
$11,211
$11,308
$11,846
Visibility Group 5
$18,495
$18,005
$17,431
$17,023
$16,528
$15,965
$16,250
$15,990
$15,803
Visibility Group 6
$1,091
$1,059
$1,221
$1,316
$1,213
$1,126
$1,116
$1,100
$1,149
Filing Status
Single/other
57%
58%
57%
57%
59%
60%
60%
61%
60%
Married filing jointly
43%
42%
43%
43%
41%
40%
40%
39%
40%
Total Exemptions
0 or NA
2%
1%
2%
2%
2%
2%
2%
2%
2%
1
32%
31%
31%
33%
33%
33%
34%
34%
35%
2
32%
33%
31%
32%
32%
32%
31%
32%
28%
3
17%
17%
17%
15%
16%
15%
15%
15%
16%
4
12%
11%
12%
12%
11%
11%
12%
11%
12%
5+
6%
7%
7%
6%
6%
6%
7%
6%
7%
Had wage income
85%
85%
85%
85%
84%
83%
85%
83%
83%
Claimed child tax credit
24%
23%
23%
21%
22%
19%
19%
19%
19%
Itemized
46%
46%
41%
39%
41%
40%
40%
39%
38%
Deducted mortgage interest
36%
37%
33%
31%
32%
30%
30%
29%
27%
Over 65
12%
13%
14%
14%
13%
13%
14%
15%
15%
Used paid preparer
66%
66%
65%
62%
63%
62%
62%
62%
59%
Filed electronically
50%
65%
71%
73%
80%
84%
84%
70%
70%
Note: These summary statistics apply to our trimmed NRP sample. Statistics are weighted by NRP sampling weights. Means are displayed for NMAs and Correct
amounts, while proportions are displayed for all other variables. Dollar-denominated variables are expressed in terms of 2018 dollars.

IRS Working Paper, January 10, 2025, Not for quotation or citation.

4 Methods
Our baseline specification models taxpayer i’s compliance in tax year t as a function of IRS
enforcement and other drivers of compliance: 10
𝑁𝑁𝑁𝑁𝑁𝑁𝑖𝑖𝑖𝑖 = 𝛽𝛽0 + 𝛽𝛽1 𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑔𝑔,𝑡𝑡−2 + 𝛽𝛽2 𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶 𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝑖𝑖𝑖𝑖 +
𝜷𝜷𝑻𝑻𝑻𝑻𝑻𝑻𝑻𝑻𝑻𝑻𝑻𝑻𝑻𝑻𝑻𝑻 𝑪𝑪𝑪𝑪𝑪𝑪𝑪𝑪𝑪𝑪𝑪𝑪𝑪𝑪𝑪𝑪𝒊𝒊𝒊𝒊 + 𝜹𝜹𝑨𝑨𝑨𝑨𝑨𝑨𝑨𝑨𝑨𝑨𝑨𝑨𝑨𝑨𝑨𝑨 𝑪𝑪𝑪𝑪𝑪𝑪𝑪𝑪𝒈𝒈 + 𝜀𝜀𝑖𝑖𝑖𝑖

(1)

We run a separate regression for each visibility group. Return-level NMA on those line items is
our main dependent variable. Since there is skewness in NMA, we winsorize NMAs to the 95th
percentile. Audit rate is the primary variable of interest. As discussed previously, each taxpayer is
assigned the audit rate for their activity code group g for the tax year in question. We lag the
audit rate by two years to reflect the delay in enforcement processing time. We hypothesize that
𝛽𝛽1 will be negative—a decrease in audit rates should lead to an increase in noncompliance.
Importantly, we control for the correct amount that should have been reported on the line items
in question, for each visibility group; this is presumably the most important determinant of what
is actually reported, and therefore the NMA. Additional taxpayer control variables refer to the
variables described in Section 3.2.2. We include fixed effects for activity code. These capture
time-invariant determinants of compliance that are unique to each activity code, unrelated to
audit rate changes. We do not include tax year fixed effects in our regressions due to our reliance
on variation over time to identify the audit rate effects. 11 Finally, all regressions are weighted by
NRP sampling weights.

Our econometric approach is most similar to Tauchen, Witte, and Beron (1993) and Hoopes,
Mescall, and Pitman (2012), who evaluate the effect of aggregate audit rates on compliance at
the micro level (while controlling for auditor assessed income or proxies thereof). One difference
from their approach is that we use lagged audit rates instead of contemporaneous ones. While a
contemporaneous audit rate reflects audit probability for the return being filed, it is unlikely that
the taxpayer knows the contemporaneous audit rate or their audit probability until the audit cycle
for that year has completed. Rather, they are more likely to be aware of historical audit rates. To
the extent that audit rates change over time (which they have), contemporaneous audit rates are
not a suitable replacement for historical ones.
Another departure from Tauchen, et al. (1993) and Hoopes, et al. (2012) is in the treatment of the
audit rates econometrically. They use an instrumental variable approach, but we don’t for two
reasons. First, lagged audit rates do not suffer from reverse causality, as taxpayers cannot
influence past audit rates through current reporting behavior and IRS cannot influence past
compliance behavior through current audits. Second, audit rates have generally declined across
the board at varying rates due to declining resources and shifts in allocation (but not in response
to improved compliance), thereby creating a natural experiment for evaluating the causal effect
of audit rates.
Since NRP samples are independent each year, our data are pooled cross-sections rather than panel/longitudinal.
Our model controls for tax law changes through the correct amount, but it does not control for any tax policy
changes that are specific to certain taxpayer groups, such as through the inclusion of activity code-tax year fixed
effects. Such effects would be collinear with our audit rate variables, which do not vary within an activity code and
tax year. In future work, we hope to include variables capturing known policy changes for certain activity codes.

10
11

IRS Working Paper, January 10, 2025, Not for quotation or citation.

5 Results
In this section, we present the results of estimating Equation (1), focusing on the main findings
related to the audit rate variable. We then translate the estimated impacts on line-item reporting
into impacts on revenue using a tax calculator. Finally, we combine revenue with cost data to
calculate the final return on investment of IRS enforcement during this time period.

5.1 Regression Results
Table 4 presents our regression results. The number of observations for each regression varies
due to the trimming of negative NMAs and “irrelevant” taxpayers (zero reported and zero true
amount) for each visibility group. Smaller sample sizes affect statistical power and may be
responsible for the lack of statistical significance on the audit rate variable for Visibility Group 3.
Audit rates have the expected negative effect on noncompliance for all visibility groups except
for Group 1, which shows a small positive effect (not statistically significant). 12 This aligns with
our hypothesis that the effect of audit rate variation is likely small or zero, given this line item is
mostly validated by automated matching programs. For Visibility Group 2, a one percentage
point increase in audit rates decreases noncompliance on a return by $139. This is a modest but
statistically significant effect. This group includes taxpayers such as retirees with
pensions/annuities income and taxpayers between jobs receiving unemployment income.
For Visibility Group 3, a one percentage point increase in audit rates decreases noncompliance
on a return by $694, but this effect is not statistically significant. However, this regression was
conducted on the smallest sample size. This income group includes partnership/S corporation
income, capital gains, and alimony income—sources of income with some limited information
reporting. These types of income are often the targets of audits, and it is likely that the lack of
statistical significance arises from sample size issues rather than from no meaningful effect.
For Visibility Group 4, a one percentage point increase in audit rates decreases noncompliance
on a return by $806 – the largest effect across all visibility groups and is statistically significant.
Income in this group is subject to very little information reporting – such as nonfarm proprietor
income, rents and royalties, farm income, and form 4797 income. This is also the visibility group
with the largest amount of noncompliance (see Figure 3) and thus more room for improvement in
compliance if audit rates were to rise.
Finally, audit rates have the expected effect on adjustments, deductions, exemptions, and credits
(Visibility Groups 5 and 6). A one percentage point increase in audit rates decreases
noncompliance on adjustments, deductions, and exemptions by $80 per return (not statistically
significant) and on refundable and nonrefundable credits by $64 per return (statistically
significant).
The result for Visibility Group 1 is consistent with a separate analysis we conducted using Automated
Underreporter (AUR) data (results are not included here for conciseness) among a sample of tax returns taken from
the entire population. AUR matches third-party information documents sent to the IRS with what taxpayers report on
their tax returns. This screens for noncompliance on line items with substantial information reporting, such as
wages and salaries. We construct a measure of NMA based on AUR-corrected line items. While NRP-adjusted NMA
is available only for NRP audits, AUR-adjusted NMA is available for all taxpayers using third-party information
documents. This approach allows us to evaluate a sample of taxpayers outside the standard NRP population for this
analysis.
12

IRS Working Paper, January 10, 2025, Not for quotation or citation.
Table 4. Regression Results†
Dependent Variable: NMA
Visibility
Group 1

Visibility
Group 2

Visibility
Group 3

Visibility
Group 4

Visibility
Group 5

Visibility
Group 6

14.07

-139.06 ***

-694.26

46.65

53.32

510.80

-806.28 *

-80.58

-63.09 ***

488.40

103.29

10.53

0.001 ***

0.008 ***

0.003 ***

0.016 ***

-0.024 ***

-0.0004 ***

0.000

0.000

0.000

0.000

0.001

0.000

Total Exemptions 1

-82.66

4.27

1,758.35

5,013.89 **

222.30

-44.04

Total Exemptions 2

112.69

138.38

1,223.25

2,031.73

-208.98 *

87.31

3,155.59 **

6,420.07 ***

119.70

148.56

1,429.04

2,166.77

-273.54 **

98.29

3,903.88 **

6,279.30 ***

126.39

157.52

1,530.01

2,252.24

-299.91 **

168.35

3,387.64 **

6,912.06 ***

133.92

164.74

1,599.40

2,338.20

-158.58

345.84 **

4,818.52 ***

7,831.20 ***

141.66

173.54

1,689.29

2,435.90

339.74

101.47

218.58 ***

-988.15 **

-3,383.41 ***

285.10 **

67.89 ***

Audit Rate (2 Year Lag)
Correct Amount

Total Exemptions 3
Total Exemptions 4
Total Exemptions 5+
Wage Income

Used paid preparer

F Statistic
Degrees of Freedom

536.63 ***

299.75
1,860.49 ***
319.44
2,271.76 ***

100.16
609.14 ***
100.83
704.55 ***

482.67

633.11

133.99

19.52

-2,958.06 ***

-313.95 **

-110.79 ***

49.96

59.51

676.53

819.15

125.75

13.20

-139.96 *

-156.35 ***

-656.25

2,399.92 ***

2,869.74 ***

3.10

73.59

60.44

550.10

886.61

157.75

22.67

30.23

192.29 ***

881.68

-2,028.66 **

-741.34 ***

-51.24 **

72.57

59.68

549.61

888.76

160.72

22.51

-182.10 **

361.39 *** -1,232.10 **

-4,639.70 ***

-187.20

52.60 **

76.122

55.306

510.240

759.367

147.722

23.007

132.68 ***

-4.05

747.70 *

957.22 *

-280.53 ***

69.49 ***

36.91

38.86

422.47

573.40

88.84

11.12

81.36 **

-90.49 **

-1,099.77 ***

-1,616.72 ***

75.57

7.15

40.48

39.19

382.35

535.43

93.87

11.98

63.30

32.21

-1,711.42 **

-12.72

-1,590.65 ***

-410.54 ***

54.97

66.04

829.94

896.88

132.89

15.35

246.38 *

365.29 **

5,425.60 ***

3,883.68

-155.02

227.57 **

147.27

185.29

1,841.59

2,373.13

360.45

102.18

91,569

83,897

55,908

77,393

118,991

64,190

N

N

N

N

N

N

0.001
4.072 ***
91,479

0.027
92.130 ***
83,847

0.009
20.887 ***
55,864

0.04
126.071 ***
77,331

0.022
104.359 ***
118,867

0.047
122.403 ***
64,132

Tax Year Fixed effect
Adjusted R2

1,981.16 ***

-882.18

Married-Joint Status

Observations

99.60

54.40

Filed electronically

Constant

282.88

-262.04 ***

Deducted mortgage int.
Over 65

99.14
308.48 ***

41.23

Claimed child tax credit
Itemized

264.20
1,553.30 ***

† Standard errors on second line.

Statistical significance: *** 1%

** 5%

* 10%

IRS Working Paper, January 10, 2025, Not for quotation or citation.

5.2 Translating Changes in Line-Item Misreporting into Changes in Revenue
The coefficients on the audit rate variable in Table 4 describe the impact of a change in audit rate
on dollars of misreporting (i.e., NMA). We translate the impact on reporting compliance into the
impact on tax revenue. Mechanically, this first involves taking the change in dollars of
misreporting for the entire visibility group (derived from the regression coefficient and the actual
change in audit rate) and allocating these changes to individual line items within the visibility
group. This allocation was done in proportion to how the detected NMAs were distributed across
line items within the visibility group on the original return – reflecting the assumption that the
rate of change in misreporting is the same for each line item in the category. Further, we ensure
these allocations are subject to the tax rules governing each line item. This process is especially
important for offset line items, which often are subject to different limitations than other items in
the same visibility group.
Table 5 illustrates how a hypothetical audit rate decline affects a hypothetical tax return.
Columns 5 and 6 show the detected amount of NMA (from the NRP audit) and the reported
amount from the NRP return. These “actuals” are the implied result of an audit rate decline two
years prior (in this example). In columns 3 and 4, we calculate the counterfactual amount
reported and the corresponding NMA had the audit rate not declined. The last column shows the
difference between the actual and the counterfactual amounts – this is the impact on this return of
the decline in audit rate.
For example, no NMA was detected on wages and salaries for the hypothetical return in Table 5
– so the counterfactual NMA remains zero due to our allocation rules. However, there was $150
of misreporting detected on interest and dividend income. This detected amount was the result of
an audit rate decline in this example – so the counterfactual misreported amount ($100) is lower.
Likewise, the counterfactual misreported amounts are lower for all line items that had a detected
NMA on this hypothetical return. Lower NMAs in turn result in higher counterfactual income
and lower offsets.
Once NMA changes are allocated to individual line items, we feed the counterfactual tax return
through a tax calculator to determine the tax liability that would have been reported on the NRP
return had the audit not changed. The bottom right box (in yellow) shows the overall impact on
tax after refundable credits (TARC) – this taxpayer would have paid $552 more in TARC had
audit rates not declined two years prior. Finally, we apply this approach to each NRP return and
apply NRP weights to calculate population-level revenue impacts of the audit rate changes.

IRS Working Paper, January 10, 2025, Not for quotation or citation.
Table 5. Illustrative Impact of a Hypothetical Audit Rate Decline on Tax Paid by a
Hypothetical Taxpayer
Visibility Line Item

$ Reported
NMA
w/o decline w/o decline

6
Tax
Offsets

5
Income
Offsets

4
Low / No

3
Limited

2
Substantial

1 High Wages & Salaries
$60,000
Pensions & annuities
Unemployment compensation
Interest & dividend income
$2,500
State income tax refunds
$500
Taxable social security benefits
Partnership / S corp. income
Trust income
Capital gains
$3,000
Alimony income
$100
Nonfarm proprietor income
$70,000
Farm income
Rents & royalties
$50,000
Form 4797 & Other income
Total Income
$186,100
Adjustments
Exemptions
$8,000
Deductions
$20,000
Tentative tax
$31,515
Nonrefundable credits
$2,600

Detected
NMA

Observed
Return

$0

$0

$60,000

$0

$100
$0

$150
$0

$2,450
$500

-$50
$0

$160
$400
$10,000

$200
$500
$11,000

$2,960
$0
$69,000

-$40
-$100
-$1,000

$4,545

$5,000

$49,545

-$455

$15,205

$16,850

$184,455

-$1,645

$0
$3,000
$5,098
$100

$0
$3,150
$5,600
$150

$8,000
$20,150
$31,013
$2,650

$0
$150
-$502
$50

$5,198

$5,750

$28,363

-$552

∆

Refundable credits
Tax after refundable credits
(TARC)

$28,915

5.3 Calculating Return on Investment
The final step of our analysis is to calculate return on investment (ROI). We combine the revenue
estimates from the prior section with data on enforcement costs. We use IRS records to calculate
the cost of audits corresponding to the audit rates used in Equation (1). We include costs
associated with the Exam, Appeals, Counsel, and Collection functions. It is important to note that
aggregate audit costs generally move in the same direction as audit rates, with a few exceptions
that likely arise from productivity changes (such as from a different mix of auditor experience or
levels year over year). We remove these handful of year-activity code observations where this is
the case.
Table 6 summarizes the direct ROI, general indirect ROI, and combined ROI for four groupings
of taxpayers based on TPI. Direct ROI is calculated from audit records and includes only the
additional tax actually paid as a result of the audit for the tax year that was audited. We see that
$1 of enforcement cost during this 2006-2014 time period generated $3.30 of direct revenue on
average and almost $9 when applied to audits of taxpayers earning $400k and above. The general

IRS Working Paper, January 10, 2025, Not for quotation or citation.
indirect ROI shown is calculated from this paper’s analysis and shows the population-level
impact of a dollar of auditing cost. We provide a range of general indirect ROIs depending on
whether we use all point estimates from Table 4 (high end) or only statistically significant
estimates (low end). $1 of enforcement cost generates around $10-$13 of general indirect
revenue, with larger impacts on taxpayers earning between $200k-$400k. 13 Finally, combined
ROI shows the total impact of a dollar of enforcement. $1 of enforcement costs generates, on
average, roughly $13-16 of total revenue when considering direct and indirect effects. (Note that
the variation in these ROIs across the TPI ranges is not directly applicable to IRS resource
allocation decisions, which should be made on the basis of the cost-effectiveness of the next
enforcement case. In contrast, the direct ROIs here are averages (total revenue divided by total
cost) and the indirect ROIs are average marginals (the change in revenue divided by the change
in cost. Nonetheless it seems likely that taking indirect effects into account would change the
mix of enforcement allocations to the various categories.)
Finally, we calculate the implied revenue loss from the audit rate declines observed from 2009 to
2012. Although this decline resulted in a $211M savings in enforcement costs, it led to an
estimated loss of almost $2.2B in voluntary tax revenue from 2011 to 2014. 14
Table 6. Return on Investment of IRS Individual Income Tax Audits, Tax Years 2006-2014
Return Total Positive Income
< $100K
$100K to under $200K
$200K to under $400K
$400K and over
All Groups

Direct ROI
2.0
2.8
3.1
8.9
3.3

General Indirect ROI
5.7 - 6.2
9.4 - 14.1
15.0 - 22.3
7.8 - 12.4
9.6 - 13.1

Combined ROI
7.7 - 8.2
12.2 - 16.9
18.1 - 25.4
16.7 - 21.3
12.9 - 16.4

6 Discussion
While most research on the impact of IRS enforcement on overall tax compliance evaluates
specific local networks, this paper contributes to a small literature on the “comprehensive”
general indirect effects of IRS enforcement. We aim to capture the effects on the entire taxpayer
population of all IRS individual income tax audits, regardless of the channels through which the
impacts propagate throughout the population. As such, these effects are relevant for IRS budget
justification, which currently cites the ROI of enforcement on direct revenue and does not
quantify overall indirect effects (IRS, 2024).
We advance understanding of the nature and magnitude of comprehensive indirect effects by
implementing several novel or rarely used approaches. Ours is one of the few papers in this area
Note that our ROI numerator uses tax amounts based on NMAs as recommended by the NRP auditors, while the
ROI denominator is the full life-cycle cost of the audits (i.e., not just the Examination cost, but also the cost of any
Appeals, Chief Counsel, and Collection activity to assess and collect the tax due). This “apples vs. oranges” ratio
yields a lower bound compared with an alternative of using only the Exam cost in the denominator. Alternatively, if
we projected the recommended amount to corresponding dollars collected, the ROI would go down, but it wouldn't
take into account changes in undetected NMAs, which are not observable. So, our ROI definition seems to reflect
the best available balance of being conservative yet realistic.
13

The net average marginal ROI of 10.3 is less than 13.1 because of offsetting increases in audit rates in some
activity codes and years.

14

IRS Working Paper, January 10, 2025, Not for quotation or citation.
to use microdata. This allows for more nuanced modeling of taxpayer behavior and the ability to
control for return-level characteristics. Departing from prior papers, we use lagged audit rates to
proxy for knowledge of IRS enforcement levels. While audit rates for the tax year at hand reflect
the true aggregate probability of audit, taxpayers (and their accountants) can plausibly know only
past audit rates. Additionally, using lagged audit rates solves the reverse causality (endogeneity)
problem; an earlier audit rate is not impacted by this year’s compliance, for example.
We find that the indirect effect of audits varies across tax return line items. The effect is larger
for items subject to less third-party information reporting and for items with large existing
noncompliance. These results are intuitive. High visibility line items such as wages and salaries
are screened by automated underreporter (document matching) programs, and misreporting on
these line items may be less sensitive to audit rates per se. On the other hand, misreporting on
line items not validated by simple document matching should be more responsive to the
enforcement actions, such as audits, that focus on those line items.
Our top-level finding is that IRS audits of individual income tax returns had a combined ROI of
13:1 to 16:1 during the 2006 to 2014 Tax Years. Put another way, the general indirect effect was
3 to 4 times larger than the direct effect. This is in line with prior studies (see Table 1) and
slightly on the lower end of the range of prior estimates. These results can be used to understand
how historical IRS budget cuts have impacted voluntary compliance and how new IRS funding
(such as through the Inflation Reduction Act) present an opportunity to reverse that trend.

6.1 Limitations and Future Research
It is important to remember that this study is focused solely on the reporting noncompliance
behavior detected on individual income tax returns, which is the largest component of IRS tax
gap estimates (IRS, 2022); it does not address the nonfiling or underpayment components of the
tax gap, nor does it encompass other types of tax. Because of this focus, the only IRS
enforcement considered so far has been audits of timely filed individual income tax returns.
Another limitation of this research is that NRP audits may not detect all noncompliance among
taxpayers with high and unreported income. This will impact the accuracy of our dependent
variable. Prior research has attempted to shed light on previously undetected offshore accounts
and passthrough income (Guyton et al., 2021) but has not explored its relation to changes in
compliance over time.
Moreover, our estimates relate just to the specific time period studied and may not be directly
generalizable to the present. This is because the relationship between audit rates and taxpayer
behavior in the general population seems to be highly dependent on things like: the distribution
of audit resources across the various categories of tax returns; the distribution of income,
deductions, and tax credits across tax returns; the extent to which other factors influence
taxpayer behavior; and the tax law in place in a given year. Although it is likely that the general
indirect effect today is similar to what we have estimated for the 2006 to 2014 time period, our
estimates are not a universal constant.
There are several near-term extensions we plan to address. We plan to deepen the theoretical
motivation for the audit rate variable and potentially change its specification to improve causal
linkages and introduce more variation. This could be done, for example, by deriving audit rates
for population sub-strata beyond Activity Code. We also hope to increase statistical power

IRS Working Paper, January 10, 2025, Not for quotation or citation.
through other means. NRP samples are limited in size (and have been declining in recent years),
affecting our ability to derive precise estimates. A potential alternative to using NRP data directly
is to impute compliance measures from NRP to the universe of tax returns. Although this would
greatly improve sample size, proper validation would need to be conducted to ensure compliance
imputations are reliable.
Finally, the ultimate goal of this research is to support IRS budget justifications by estimating the
ROI of all IRS activities. IRS service, outreach, education, and IT investments plausibly have an
impact on compliance, as well. These IRS services help taxpayers become more informed and
better equipped to report and pay their taxes correctly at the outset. To account for this, we hope
to incorporate into future iterations of this work measures such as IRS website hits and level of
service. Although we focus on individual taxpayers in this paper, prior research indicates that
corporations track IRS enforcement activities in their accounting practices (Hoopes, Mescall, and
Pitman, 2012). Estimating the indirect effect of enforcement on corporate voluntary compliance
is another area of future work.

IRS Working Paper, January 10, 2025, Not for quotation or citation.

7 References
Allingham and Sandmo 1972. Income Tax Evasion: A Theoretical Analysis. Journal of Public
Economics. 1:323-338.
Alstadsæter, Annette, Wojciech Kopczuk and Kjetil Telle. 2019. “Social Networks and Tax
Avoidance: Evidence from a Well-Defined Norwegian Tax Shelter.” International tax and
Public Finance 26: 1291-1328. https://doi.org/10.1007/s10797-019-09568-3
Badgley, Ellen, Kyle Furlong, Lucia Lykke, Leigh Nicholl and Alan Plumley. 2021. “Audit
Contagion? Investigating the General Indirect Effect of Audits Through Tax Preparer
Networks.” The IRS Research Bulletin: Proceedings of the 2021 IRS/TPC Research
Conference. Publication 1500 (Rev. 5-2022)
Bergolo, Marcelo, Rodrigo Ceni, Guillermo Cruces, Matias Giaccobasso, and Ricardo PerezTruglia. 2018. Policy Implications of Suboptimal Choice: Theory and evidence. AEA Papers
and Proceedings. 108:83-87.
Bohne, Albrecht, and Jan Sebastian Nimczik. 2018. “Information Frictions and Learning
Dynamics: Evidence from Tax Avoidance in Ecuador.” Institute of Labor Economics
Discussion Paper Series. No. 11536. https://docs.iza.org/dp11536.pdf
Boning, William C., John Guyton, Ronald Hodge, and Joel Slemrod. 2020. “Heard It Through
the Grapevine: Direct and Network Effects of a Tax Enforcement Field Experiment.” Journal
of Public Economics 190: 104261. https://doi.org/10.1016/j.jpubeco.2020.104261
Chetty, Raj, John N. Friedman, and Emmanuel Saez. 2013. “Using Differences in Knowledge
Across Neighborhoods to Uncover the Impacts of the EITC on Earnings.” American
Economic Review 103(7): 2683-2721. https://www.jstor.org/stable/pdf/42920668.pdf
Department of the Treasury. 2019. “FY 2019 Budget in Brief: Internal Revenue Service, Program
Summary by Budget Activity.” https://home.treasury.gov/system/files/266/16.-IRS-FY-2019BIB-FY2019.pdf
Drago, Francesco, Friederike Mengel, and Christian Traxler. 2020. “Compliance behavior in
networks: Evidence from a field experiment.” American Economic Journal: Applied
Economics 12.2: 96-133.
Dubin, Jeffrey A., and Louis L. Wilde. 1988. “An empirical analysis of federal income tax
auditing and compliance.” National Tax Journal 41(1): 61-74.
https://www.jstor.org/stable/41788709
Dubin, Jeffrey A., Michael J. Graetz, and Louis L. Wilde. 1990. “The Effect of Audit Rates on
the Federal Individual Income Tax, 1977-1986.” National Tax Journal 43(4): 395–409.
https://www.jstor.org/stable/41788861
Dubin, Jeffrey A. 2007. “Criminal investigation enforcement activities and taxpayer
noncompliance.” Public Finance Review 35(4): 500-529.
https://authors.library.caltech.edu/99369/1/sswp1200.pdf
Erard, Brian (1992). “The Influence of Tax Audits on Reporting Behavior.” In Why People Pay
Taxes: Compliance and Enforcement, edited by Joel Slemrod.

IRS Working Paper, January 10, 2025, Not for quotation or citation.
Grana, Jess, Nelson Foster, Navya Kambalapally, India Lindsay, Betsy Lydon, Max McGill,
Alexander McGlothlin, and Brian Rhindress. 2022. “Indirect Effects Research and Support.”
MITRE Technical Report.
Grana, Jess, India Lindsay, Lucia Lykke, Max McGill, Alexander McGlothlin, Leigh Nicholl,
Alan Plumley. 2024. “The specific indirect effect of IRS audits.” International Tax and
Public Finance. https://doi.org/10.1007/s10797-024-09866-5
Guyton, John, Patrick Langetieg, Daniel Reck, Max Risch, and Gabriel Zucman. 2021. “Tax
evasion at the top of the income distribution: Theory and evidence.” National Bureau of
Economic Research, No. w28542.
https://www.nber.org/system/files/working_papers/w28542/w28542.pdf
Hoopes, Jeffrey L., Devan Mescall, and Jeffrey A. Pittman. 2012. “Do IRS audits deter corporate
tax avoidance?” The Accounting Review 87(5): 1603-1639.
https://www.jstor.org/stable/pdf/41721904.pdf
Internal Revenue Service. 2022. “Federal Tax Compliance Research: Tax Gap Estimates for Tax
Years 2014-2016.” Publication 1415 (Rev. 08-2022). https://www.irs.gov/pub/irspdf/p1415.pdf
Internal Revenue Service. 2024. “Fiscal Year 2025 Congressional Budget Justification & Annual
Performance Report and Plan.” Publication 4450 (Rev. 2-2024). https://www.irs.gov/pub/irspdf/p4450.pdf
Keppler, Mazur and Nagin. 1991. Expert Intermediaries and Legal Compliance: The Case of Tax
Preparers. The Journal of Law & Economics. 34(1): 205-229.
Lopez-Luzuriaga, Andrea, and Carlos Scartascini. 2019. Compliance Spillovers Across Taxes:
The role of penalties and detection. Journal of Economic Behavior and Organization.
164:518-534.
Meiselman, Ben S. 2018. “Ghostbusting in Detroit: Evidence on nonfilers from a controlled field
experiment.” Journal of Public Economics 158: 180-193.
https://doi.org/10.1016/j.jpubeco.2018.01.005
Perez-Truglia, Ricardo, and Ugo Troiano. 2018. “Shaming tax delinquents.” Journal of Public
Economics 167: 120-137. https://doi.org/10.1016/j.jpubeco.2018.09.008
Plumley, Alan. 1996. “The Determinants of Individual Income Tax Compliance.” Department of
the Treasury, Internal Revenue Service, Publication 1916 (Rev. 11-96).
Pomeranz, Dina. 2015. “No taxation without information: Deterrence and self-enforcement in the
value added tax.” American Economic Review 105(8): 2539-2569.
https://www.jstor.org/stable/pdf/43821348.pdf
Slemrod, Joel, Marsha Blumenthal, and Charles Christian. 2001. “Taxpayer response to an
increased probability of audit: evidence from a controlled experiment in Minnesota.” Journal
of Public Economics 79(3): 455-483. https://doi.org/10.1016/S0047-2727(99)00107-3

IRS Working Paper, January 10, 2025, Not for quotation or citation.
Tauchen, Helen V., Ann Dryden Witte, and Kurt J. Beron. 1993. “Tax Compliance: An
Investigation Using Individual Taxpayer Compliance Measurement Program (TCMP) Data.”
Journal of Quantitative Criminology 9: 177-202. https://www.jstor.org/stable/23365801

IRS Working Paper, January 10, 2025, Not for quotation or citation.

8 Appendix
Figure 4. Audit Coverage* Trend Among Individual Income Tax Returns, TYs 2006-2014

Note: Plots the overall decline in audit coverage among individual income tax returns during Tax Years (TYs) 20062014.* Coverage rate = (number of returns audited) / (total number of returns filed) for the tax year

IRS Working Paper, January 10, 2025, Not for quotation or citation.
Table 7. IRS Examination Activity Code Definitions
Activity Description
Code

Percent of
Population

Group

270

EITC present & TPI < $200,000 and Schedule C/F TGR <
$25,000 or EITC w/o Sch C/F (As of TY 2008)

17.1%

EITC

271

EITC present & TPI < $200,000 and Sch C/F TGR >
$24,999 (As of TY 2008)

1.2%

EITC

272

TPI < $200,000, no Sch C, E, F, or Form 2106 (As of TY
2008)

55.3%

Non-Business
Mid-Income

273

TPI < $200,000 and Sch E or Form 2106, no Sch C or F
(As of TY 2008)

10.8%

Non-Business
Mid-Income

274

Non-Farm Business w/ Sch C/F TGR < $25,000 and TPI <
$200,000 (As of TY 2008)

7.3%

Business

275

Non-Farm Business w/ Sch C/F TGR $25,000 - $99,999
and TPI < $200,000 (As of TY 2008)

2.1%

Business

276

Non-Farm Business w/ Sch C/F TGR $100,000 - $199,999
and TPI < $200,000 (As of TY 2008)

0.6%

Business

277

Non-Farm Business w/ Sch C/F TGR > $199,999 and TPI
< $200,000 (As of TY 2008)

0.5%

Business

278

Farm Business Not Classified Elsewhere and TPI <
$200,000 (As of TY 2008)

0.9%

Business

279

No Sch C or F and TPI > $199,999 and < $1,000,000 (As
of TY 2008)

2.4%

Non-Business
High-Income

280

Sch C or F present and TPI > $199,999 and < $1,000,000
(As of TY 2008)

1.0%

Business

281

TPI > $999,999 (As of TY 2008)

0.3%

Non-Business
High-Income

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Airs%3A7ada4e404fd4f6f2. Public record. Not legal advice.