# GrossTax Gap EstimatesandProjections

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

## Text

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Income Tax
Compliance
Research
I

GrossTax Gap EstimatesandProjections
for 1973-1992

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Departmentof the Treasury
Internal Revenue Service
ResearchDivision
Publication 7285 (3-88)

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~fet1~rtment In com e Tax
C
.
Treasury
Internal
Om
p llanCe
Revenue

Research

Service

Gross Tax Gap Estimates and Projections
for 1973-1992
Publication7285
March1988
~
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Lawrence B. Gibbs
Commissioner
John L. Wedick, Jr.
Deputy Commissioner
(PlanningandResources)
John D. Johnson
AssistantCommissioner
(Planning,FinanceandResearch)
Frank M. Malanga
Director, ResearchDivision

This reportcontainsthe InternalRevenueService'snew
estimatesof the grossincometax gap. Earlier estimateswere
revisedto reflect recenttax law changes,recentcompliance
data,andimprovementsin tax gapestimationmethods.
For additionaldetailon the methodsusedto derivethe estimates,
write to: Chief, ComplianceAnalysisGroup,
ResearchDivision (PFR:R),InternalRevenueService,
1111ConstitutionAvenue,N.W., Washington,DC 20224.
Alternatively,for the additionalinformation,call:
(202) 376-0720.

Irene W. Sherk
AssistantDirector, ResearchDivision
Dennis R. Cox
Chief, ComplianceAnalysisGroup
Berdj Kenadjian
Chief Economist
,1
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(Compliance Estimates)

II

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Suggested Citation
InternalRevenueService
IncomeTax ComplianceResearch:
GrossTax GapEstimatesandProjectionsfor 1973-1992
Publication7285(March 1988)
Washington,DC 20224

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Tax Gap Estimatesand Projectionsfor 1973-1992

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Table of Contents
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Page

Table of Contents

ii

List of Tables and Charts

iii

Introduction

iv

Chapters:

I. The Estimates """""""""""""""""""""""""""

1

A. Definitions

1

B. Noncompliance in 1987

1

1. Individual GrossTax Gap for 1987 ..

2

2. Corporation Gross Tax Gap for 1987

4

C. Voluntary Reporting Percentages

4

1. Individual VRPs for 1987

4

2. Corporation VRPs for 1987 """"""""""""""""""'"

6
6

D. Trends

ll. Comparisons With Prior IRS Estimates
9
A. Shift of Tax Liabilities from Individualsto Corporations... . . . . . . . 9
B. New Data
9
C. ImprovedMethods
11
D. RemittanceGap
,
11
1lI.

Methodology

,

A. Filers of Individual Returns
B. Individual Nonfilers of Returns
C. Corporations
1. Small Corporations
2. Large Corporations
3. "Other" Tax Gap

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13
15
15
15
16
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Tax Gap Estimates and Projections for 1973 -1992

List of Tablesand Charts
Page

Tables:
1-1. Distribution of the GrossIncomeTax Gapby Source,
Tax Year 1987

3

1-2. ReportedandUnderreportedIncomes,OverstatedItemsand
Voluntary ReportingPercentages
(VRPs)for Individual
Tax Return Filers,Tax Year 1987

5

1-3. GrossTax GapsandVoluntary ComplianceRates,Selected
Tax Years, 1973-1992

7

11-1. DifferencesBetweenOld andNew GrossTax GapEstimates
for Tax Years1981and 1987by Reasonfor Change

10

Charts:
1.
2.

RevisedEstimatesof the GrossTax Gap,Tax Year 1987
2
Estimatesof the GrossTax Gapby Major Component,Selected
Tax Years,1973-1992
6

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Tax Gap Estimatesand Projections/or 1973-1992

Introduction

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The mission of the Internal Revenue Service is to collect the proper amount of tax
revenue at the least cost to the public, and in a manner that warrants the highest degree of
public confidence in our integrity, efficiency and fairness. To achieve this purpose, IRS
must determine the extent of noncompliance with the tax law and regulations. The tax gap is
a comprehensive measure of noncompliance which conveys significant information on the
challenges faced in collecting taxes that are not voluntarily paid. This report presents IRS's
revised estimates of the gross tax gap, which is the amount of income tax owed but not
voluntarily paid. The "net tax gap" is the gross tax gap less taxes paid as a result of IRS
enforcement activity.1 In this report the words "gap" or "tax gap" always refer to the gross
tax gap.
The tax gap consists of unpaid individual and business income taxes on legally
earned income. The gap exists becausesome individuals and businessesunderstateincome,
overstate deductions, credits, and exemptions, and make math errors on the tax returns they
file. It exists also because some do not file the tax returns they are required to file, and
because some do not voluntarily pay taxes they report. (This report, however, does not
contain estimates for taxes reported but not paid.) The tax gap estimates presented in this
report do not include gaps resulting from failure to report employment or excise taxes, or any
tax other than the Federal income tax.
IRS has revised the tax gap estimatesfor 1987 and forward in order to reflect effects
of recent tax legislation on individual and corporation income tax liabilities, the availability of
more recent data, and improvements in estimating methods. The estimates are projected
forward to 1992. Chapter I presents the tax gap estimates in detail for 1987 and analyzes
trends and projections through 1992. Chapter n compares the new with the old estimates
and discusses the reasons why the new estimates are lower than those published in 1983.
(The previous IRS tax gap estimates appeared in Income Tax Compliance Research:
Estimates for 1973-1981, published in July 1983.) Chapter ill describes the methods used
in making the estimates.

1 IRS annually collects over $20 billion of income tax through enforcement programs. Estimates of the net tax
gap are currently being developed for publication in a later report. The report should be available in the
summer of 1988.
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Tax Gap Estimatesand Projections/or 1973-1992

Page 1

Chapter I
The Estimates

IRS estimates the gross income tax gap for tax year (TY) 1987 to be
$84.9 billion. This consists of a $63.5 billion gap for individuals and a $21.4 billion
corporate gap. This chapter explains what these gap estimates measure,discussesindividual
and corporate noncompliance in 1987, and setsthe 1987 tax gap in the context of preceding
years and projections through 1992.
A. Definitions
The income tax gap is the amount of income tax owed for a given year, but not
voluntarily paid. The word "voluntarily" means without actual enforcement action, such as
examination, collection, or criminal investigation. These estimates do not correspond
directly to any figures in the budget of the Federal Government. IRS, through enforcement
programs, does assessand collect part of what taxpayers owe but do not voluntarily pay and,
thus, closes part of the tax gap. The tax gap estimates in this report do not net out this
enforcement revenue, however; nor do they include penalties and interest, which Federal
budget receipts include. Although the estimatesprepared for this report are called gross tax
gap measures,they are net of tax which is voluntarily overreported.
The unreported income estimates should not be equated with income earned in the
so-called "underground economy." Press reports and scholarly works have defined the
underground economy in various ways. In particular, it is not clear which types of business
activities should be included. Such ambiguities make this "economy" more a figure of
speech than an operational concept that can be measured. Further, this term usually
encompassesboth illegal and legal transactions. Although income from illegal transactionsis
taxable, it is extremely difficult to measure and to tax, and is therefore not included in the
estimates prepared for this report. IRS estimates, besides accounting for unreported income
earned in the regular economy, also account for noncompliance in the legal portion of the
underground economy, such as unreported informal supplier income and unreported tip
income. (Informal suppliers include roadside or sidewalk vendors, moonlighting craftsmen
or mechanics, unlicensed providers of child or elderly care services, and similar operators
with informal business styles.)
B. Noncompliance

in 1987

The estimatesof noncompliance in 1987 are essentially projections from earlier data.
Tax year 1982 is the latest year for which we have compliance data for individual taxpayers.
We based the 1987 tax gap figures on the assumption that voluntary reporting percentages
(VRPs-amounts reported expressed as percentages of amounts which should have been
reported) have remained at 1982 levels for each income, deduction, and credit item.
(Estimated effects of the compliance provisions of the 1982, 1983, 1984 and 1986 tax acts
were superimposed on this baseline.) Notwithstanding the assumption of constant VRPs,
recent tax legislation will reduce the individual income tax gap by reducing the number of tax
items that may be overreported and by lowering marginal tax rates.

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Tax-Gap
Estimates
andProjectionsfor
1973-1992

Page2

1. Individual GrossTax Gapfor 1987
As Chart 1 and Table 1-1 show, individual taxpayers who file returns but
underreporttheir tax liabilities accountfor most tax dollars lost to noncompliance.For TY
1987,we estimatethe fIler tax gapto be $56.3billion, which is almosteight times aslarge as
the gap resulting from individuals who fail to file required tax returns. There are three
sourcesof this gap: underreportedincome, overstatedsubtractions(itemized deductions,
adjustments,and exemptions)and credits, and "math errors." Of the three parts, income
underreportedby individual filers contributesby far the largestamountto the tax gap. In
1987,this amountedto $48.3 billion. Nonfarm and farm sole proprietor incomesaccount
for over half ($26.3billion) of this amount
Chart 1. Revised Estimates of the Gross Tax Gap (in billions),
Tax Year 1987
Total:

$84.9 billion

..""","'"

,...

,.".".,
Corporations
($21.4)

"..,

. ,. ,. ,. ,. Net Math Error ($1.0)
,."",."",.""
",." Overstated
,. ,. ,.,.
Sb
.
u tractions
andCredits($7.0)
U nderreported

Income($48.3)
Individual
Nonfilers
($7.2)

Individual
Filers
($56.3)

In Table 1-1, tax on underreported
" nonfarm
,
proprietor income is divided into two

major parts. First, an estimated$7.7 billion of tax on underreportedproprietor incomewas
earnedby "informal suppliers"who tend to operate"off the books." Second,about $16.6
billion of the tax gap was due to understatednonfarm businessincome of self-employed
individuals operating in more conventionalways. Tax on underreportedfarm proprietor
incomeis $1.9 billion.
Table 1-1combinespartnershipincomeand smallbusinesscorporationdistributions
to individuals.2 Inadequatereporting of these incomes on 1987 returns contributed an
estimated$3.2 billion to the tax gap. Underreportednetrent androyalty incomeaccountsfor
$3.1 billion. Failure to report capital gains contributedanother$6.6 billion, while
underreportedinterestand dividendsaccountsfor $3.2 billion. The shortfall in reportedtax
due to underreportedwages,salaries,pensionsand annuitiesis approximately$1.5 billion.
2 The net income of a qualified small business corporation (defined in section 1371 of the Internal Revenue
Code), whether or not distributed, is taxed as ordinary income through each stockholder. Theretore, it is quite
similar to partnership income for tax purposes.

Tax Gap Estimatesand Projections/or 1973-1992

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Table 1-1. Distribution of the Gross Income Tax Gap by Source,
Tax Year 1987

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![

Sourceof Gap

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Total Income Tax

84,874

100.0

f

Individual Income Tax

63,475

74.8

:

Filersof taxreturns

56,301

66.3

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TaxGap

($ millions)

Underreported
income

Percentage
Distributions
ofilie Tax Gap

48,292

56.9

1,417
3,227
6,650
7,739

1.7
3.8
7.8
9.1

16,646
1,904

19.6
2.2

3,216
123
3,141
64
86
173

3.8
0.1
3.7
0.1
0.1
0.2

338
3,566

0.4
4.2

6,062
545
3,478
2,039

7.1
0.6
4.1
2.4

Credits

899

1.1

Maili Errors

1,049

1.2

Wagesandsalaries
Interestanddividends
Capital gains
Informal suppliers1
Oilier nonfarmproprietor
iocome
Farm income
Partnershipand small
businesscorporationincome
Pensionsand annuities
Rentsandroyalties
Estateand trust income
Stateincometax refunds
Alimony income
Taxableunemploymentand
Social Securitybenefits
Oilier income
Overstatedsubtractions
Adjustments
Deductions
Exemptions

Nonfilers of tax returns

7,174

8.4

Income Tax

21,399

25.2

Small corporations
(assetsunder $10 million)

5,225

6.2

Corporation

Unreportedincome
Overstateddeductions
Largecorporations
(assetsof $10 million or more)
Oilier 2

2,519
2,706

3.0
3.2
15,845
329

18.7
0.4

1 Infonnal suppliers are proprietors who operate with infonnal businessstyles. See page 1.
2 Consists of $1.64~illion gap for fiduciaries and $165 million gap for unrelated business income of tax
exempt organIzatIons.
Note: Details do not add due to rounding.

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Tax Gap Estimatesand Projectionsfor 1973-1992

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The remaining $4.2 billion is attributed to estateand trust income, underreported stateincome
tax refunds, alimony, taxable social security and unemployment insurance payments, and
other income. "Other income" consists of such items as prizes, awards, gambling profits,
recovery of bad debts, insurance received as reimbursement for medical expensesincurred in
a previous year, and deductions for carryovers or carrybacks of business net operating
losses.
2. Corporation Gross Tax Gap for 1987
The corporation tax gap estimates shown in Table 1-1 refer to filers of corporate

]

returns.
Due toexpenses
lack of specific
compliance
data for
large
unreported income
and overstated
appearas
separatesources
only
for corporations,
small corporations.

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The fIrSt column of Table 1-1 shows that large corporations ($10 million or more in
assets),with a tax gap of $15.8 billion, dominate the total corporate tax gap of $21.4 billion.
The relative sizes of the gaps largely reflect the much larger aggregate tax liability of large
corporations. Small corporations (less than $10 million in assets)account for $5.2 billion of
the total, split almost equally between underreported income and overstated deductions and
credits.

c. Voluntary Reporting Percentages
Voluntary reporting percentages(VRPs) measurethe relationships between the total
amounts of income or other related items that are voluntarily reported for any given year, and
the corresponding correct amounts that should have been reported for that year. The correct
amounts depend on the income tax provisions of the Internal Revenue Code in effect for that
year as well as such things as the strength of the economy during that year.
1. Individual VRPsfor 1987
Noncompliance means reporting too little or too much tax, income, or any of the
various deductions or credits that taxpayers may subtract from tax or income.
Underreporting or overreporting is measured on a net basis. Ordinarily, taxpayers
underreport incomes more frequently than they overreport them. Consequently, VRPs for
income items are less than 100 percent. Conversely, offsets to tax or income, such as credits
and exemptions, are overreported more frequently than they are underreported.
Consequently,VRPs for these items generally exceed 100 percent.
Table 1-2 shows estimates of how much income and offsets to income individual
filers underreported or overreported in 1987, along with the corresponding VRPs. Note that
these estimates do not reflect nonfiler noncompliance. Estimates of unreported nonfiler
income can be misleading becausetax on such incomes has frequently been fully or partially
paid, principally through withholding of tax by the taxpayer's employer. Thus, for tax year
1987, although delinquent nonfiler' incomes totaled $158.7 billion, the nonfiler tax gap was
only $7.2 billion (see Table 1-1). Moreover, data on nonfilers, available only for 1972 and
1977, are much less conclusive than data on filers, whose returns are scientifically sampled
and thoroughly examined.

3 We distinguish delinquent nonfilers from legitimate nonfilers who are not required to file tax returns since
their total incomes fall below the filing thresholds. Legitimate nonfilers do not contribute to the tax gap.

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TaxGapEstimates
andProjectiO7Lrfor
1973-1992

Table

Page 5

1-2. Reported and Underreported Incomes, Overstated Items and
Voluntary Reporting Percentages (VRPs) for Individual
Tax Return Filers, Tax Year 1987
Amount
Reported
($ millions)

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Total Income of Filers

2,750,292

Wagesandsalaries

Interest
anddividends

AmountUnder/
OverreJX>rted VRP 1
($ millions)
247,734

91.7

2,051,093

9,427

99.5

229,078

13,153

94.6

Capital gains
Informal suppliers2
Other nonfarmproprietorincome

191,002
7,740
89,330

25,261
51,417
86,018

88.3
13.1

Farmproprietor
income

-11,313

11,289

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Partnershipand small business
co1]JOI'ation
income
Pensionsand annuities
Rentsand royalties
Estateand trust income
Stateincometax refunds
Alimony income
Taxableunemployment
TaxableSocial Securitybenefits
Otherincome3

10,607
125,589
67
15,138
9,287
3,341
16,113
10,785
2,435

14,589
2,103
15,715
285
463
1,362
1,965
364
14,323

867,345

36,522

104.4

Adjustments
Deductions

36,686
390,189

2,186
16,555

106.3
104.4

Exemptions

440,470

17,781

104.2

2,078,015 4

284,254

88.0

Total

Subtraction

Taxable

Income

Items

of Filers

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98.4
98.2
95.2
71.0
89.1
96.7

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1 Five VRPs are not shown becausethey would be distorted by the combination of positive and negative
amounts of income. The VRPs that are shown would have been lower if the unreported incomes of nonfilers
had been included.
2 Informal suppliers are proprietors who operate with informal businessstyles. See page 1.
3 Includes deductions for carryovers and carrybacks of businessnet operating losses.
4 Reported taxable income exceedstotal reported income less subtractionsbecause,for returns with subtractions
greater than income, taxable income is zero.

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In tax administration,it is axiomaticthat whenthird partiesrepon to the tax agency
the incometheypay to individuals,compliancein reportingsuchincomemarkedlyimproves.
Withholding tax at the sourcehasproven to be an even more effective meansof assuring
compliance. Due to the variety of circumstances
underwhich incomeis earnedandpaid in a
modem economy,one cannot precisely quantify the impacts of information reporting or
withholding on compliance. Nevenheless,the VRPs in Table 1-2 reflect the positive
influenceof withholding andinformationreportingon compliance.
For example, a very large ponion of wage and salary income is covered by
withholding, and we estimatethe VRP for wagesand salariesto be 99.5 percentfor filers.
The VRP for pensionsand annuitiesis almostashigh-98.4 percent. Although withholding
is optional to the taxpayer, pensions and annuities are almost universally covered by

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Tax Gap Estimatesand Projectionsfor 1973-1992

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infonnation reporting. At the other extreme, when IRS has no infonnation on the incomes
earned and taxpayers keep poor books and records, compliance tends to be very low. For
example, we estimate the VRP for infonnal supplier income to be only 13.1 percent.
Most interest and dividend income is covered by infonnation reports. However,
substantial amounts of interest and dividends, particularly when received from abroad, are
not subject to infonnation reporting. Infonnation reporting for capital gains is less complete
than for interest and dividends. For example, brokers' reports to IRS are limited to
infonnation on the sale of their clients' publicly traded securities. Reflecting the more limited
infonnation IRS receives from third parties, the estimated filer VRPs for interest and
dividends and capital gains are 94.6 percent and 88.3 percent, respectively.
Notice that Table 1-2 does not present VRPs for some income categories. When a
particular income type can be negative as well as positive, the VRP may become inaccurate.
Moreover, negative values included in the aggregate for an income type will distort VRPs
even if the aggregatein question is positive.
2. Corporation VRPsfor 1987
VRPs cannot be calculated for large corporation income and deduction items because
specific data on what should have been reported are not available. (Taxpayer Compliance
Measurement Program [TCMP] studies have not been conducted for large corporations.) In
the caseof small corporations, for which TCMP studies are available, the VRPs for 1987 are
97.3 percent for total income reported (after expansion for unreported income not detectedin
TCMP-see page 15) and 101.4 percent for deductions reported.

D. Trends
Knowledge of income tax compliance patterns for a given year is vital for effective
tax administration. However, compliance trends also provide important infonnation. These
Chart 2..Estimates of the Gross Tax Gap by Major
Selected Tax Years, 1973-1992

Component,

,-.. 100
120

f/}
=
0

S
.0

80

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60
40

...

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20

...

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73

76

79

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Individuals

82
Tax Year

.

85 86 87 88 89 90 91 92
Corporations

Tax Gap EstimatesandProjectionsfor 1973-1992

Table 1-3. Gross Tax Gaps and Voluntary Compliance Rates, Selected Tax
Years, 1973-1992

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1973

1976

1979

1982

1985

1986

1987

1988

1992

Total

28.4

40.7

61.7

62.6

87.8

95.0

84.9

87.1

113.7

Individuals

19.7

29.6

46.8

51.9

73.3

79.3

63.5

64.3

82.6

Filers

17.9

26.8

42.3

46.2

65.5

71.2

56.3

56.9

72.4

Understated
income
Overstateddeductions
OverstatedcreCUts

15.4
2.4
-0.1

24.6

2.0
-0.3

36.4
4.7
0.6

38.1
6.5
0.9

54.6
8.6
1.2

60.0
8.9
1.3

48.3
6.0
0.9

48.5
6.1
1.1

62.8
6.8
1.3

~d1errors

0.2

0.2

0.5

0.7

1.0

1.0

1.0

1.1

1.5

Tax Gapl

($ billions)

r{onfuers

1.8

2.8

4.5

5.7

7.8

8.1

7.2

7.3

10.2

Corporations 2

8.8

11.1

15.0

10.7

14.4

15.6

21.43

22.8

31.1

Voluntary

Compliance

Rate

(percent)

Total

83.7

82.4

81.7

83.4

81.6

81.1

83.2

83.6

84.2

Individuals
Corporations 2

84.6
81.3

82.6
81.6

81.8
81.3

83.7
81.8

81.6
81.7

81.0
81.7

83.5
82.5

84.0
82.4

84.9
82.5

Source: See text.
1 Alternate estimates,based on tax that would be assessedafter all appeals,are shown below. See page 8.
1973

1976

1979

1982

1985

1986

1987

1988

1992

Gross Tax Gaps (in $ billions)
Total
23.7
34.2
Individuals
17.5
26.3
Corporations 2
6.2
7.8

52.0
41.4
10.6

53.9
46.3
7.6

75.5
64.8
10.7

81.1
70.1
11.0

71.2
56.1
15.1

72.8
56.8
16.0

95.0
73.1
21.9

Voluntary

Compliance
Total
Individuals
Corporations 2

Rates (in

percent)

86.0

84.8

84.1

85.3

83.8

83.4

85.6

85.9

86.6

86.1
85.9

84.3
86.2

83.6
86.0

85.2
86.3

83.4
85.8

82.9
86.4

85.1
87.0

85.6
86.9

86.4
87.1

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2Includes the tax gaps for fiduciaries and unrelated businessincome tax of tax-exempt organizations.
3The increase in the corporate tax gap from an estimated $15.6 billion in 1986 to an estimated $21.4

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billion in 1987 is attributable to the increase in corporate tax liabilities due to tax law changesenacted in
1986 and to the increase in corporate profits.

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trendsare illustrated in Chart 2, and aredetailedin Table 1-3. The estimatesof the total tax
gapin currentdollars showan increasefrom $28 billion for 1973to $62 billion for 1979and
to $85 billion for 1987. The gapis projectedto increaseto $114billion for 1992.
The estimatedgrowth of the tax gapis duein largepart to the growth of incometax
liabilities through real expansionof the economyand through inflation. The growth rate
alsoreflectschangesin the voluntarycompliancerate (VCR), which for eachyearis the total
amount of tax voluntarily reported as a percent of total tax liability. For example, the

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Tax Gap Estimatesand Projections/or 1973-1992

Page 8

individual gap grew rapidly from 1973 to 1979, but from 1979 to 1982 it grew at a much
slower rate. This change in the growth rate reflects corresponding changes in the VCR for
individuals, which decreased from 84.6 percent in 1973 to 81.8 percent in 1979, and
increased back to 83.7 percent in 1982. The most recent year for which TCMP data exist for
individuals is 1982. For years after TY 1982, IRS assumedthat the VRP for each source of
individual income (e.g., sole proprietor income or wage income) and for each deduction item
remained constant.
Some types of income, such as proprietor income, are not reponed as completely as
other types. Consequently, when the relative importance of the more poorly-reponed types
increases in response to changing economic conditions, the VCR for individual income tax
declines. Thus, the individual VCR declined from 83.7 percent in 1982, a recession year, to
81.6 percent in 1985, a year of expansion. The combined influence of a period of
prosperity, which enlarged the tax base, and the decline in the VCR accelerated the growth
rate of the individual tax gap from 1982 through 1985.
The tax gap estimates themselves, however, were lowered for years after 1982 to
account for the expected impact of all recent tax law changes designed to improve
compliance. The drop in the individual tax gap from $79.3 billion in 1986 to $63.5 billion in
1987 is primarily due to the reduction of individual income tax liabilities enacted in 1986.
This legislation lowered marginal tax rates, but it also repealed or limited many deductions
from taxable income, thereby minimizing the possibility for taxpayers to overstate these
income offsets.

1:1

Corporate compliance data over time are quite limited. Consequently, in estimating
and projecting the total corporate tax gap, essentially one composite VCR was used to
represent corporate compliance for all years. The decline in the corporate gap from an
estimated $15.0 billion in 1979 to an estimated $10.7 billion in 1982 does not reflect VCR
changes, but rather the drop in corporate tax liabilities over that period due to the two
back-to-back recessionsof 1980 and 1981-1982 plus tax cuts enacted in 1981. The increase
in the corporate tax gap from an estimated $15.6 billion in 1986 to an estimated $21.4 billion
in 1987 is attributable to the increase in corporate tax liabilities enacted in 1986 and to the
increase in corporate profits. The VCR for all corporations in TY 1987 was approximately
82.5 percent.
The primary estimatesfor individual filers and corporations depend on the results of
audits of tax returns. The recommendations of the IRS examiners are the basis for our
estimates of tax liabilities, and of tax gaps. Taxpayers are, of course, provided the
opportunity to contest the recommendations of IRS examiners. In some cases, the appeals
processesreverse the examiners' recommendations in part or altogether. In these cases,the
amount of additional tax assessedis smaller than the amount recommendedby the examiners.
Our alternate estimates, shown in a footnote to Table 1-3, reflect the difference
between the amounts recommended and assessed.The adjustments are based on data from
the Audit Information Retrieval System (AIRS), which tracks aggregaterecommendationsof
tax change, including recommendations made on TCMP examinations, through assessments
of additional tax. This system does not state the issues (underreponed income vs. overstated
subtractions) on which recommendations were reduced. Thus, the alternate estimates are not
available by source, and the aggregate alternate estimates cannot be derived precisely from
the primary estimates. Furthermore, in using the AIRS data, we were not able to account for
the following considerations: (1) in some cases,IRS appealsofficers settle for less than the
full liabilities to avoid the hazards and costs of litigation; (2) taxpayers whose audits did not
reveal deductions, businessexpenses,exemptions, or adjustmentswhich they had overstated
on their returns do not appeal; (3) taxpayers who disagree with their examiners'
recommendations for small increasesin tax may not appeal.
c:,
.'~

-Tax Gap Estimatesand Projectionsfor 1973-1992

Page 9

Chapter II

Comparisons With Prior IRS Estimates
.

The previous IRS tax gap estimates, published in 1983, were based largely on

!

1

1

compliance data on individuals for 1976 and earlier years. For large corporations, the most

recentcompliancedatausedwerefrom examinationsclosedin 1980;for small corporations,

1

the most recent data came from a TCMP study of firms with accounting periods centered
around tax year 1977. The revised estimates incorporate compliance data on individuals
derived from TCMP examinations of returns filed for TYs 1979 and 1982. The revised
compliance estimates for corporations are basedon examinations closed as recently as 1986.
This report also incorporates data from a 1985 household survey that provided information
on informal suppliers working "off the books," and from other special studies.

I

In addition to these new data, significant improvements in estimation methods and
changes in the tax laws have contributed to making the old estimates out of date. The
estimates in this report, therefore, replace those published in 1983. Our analysis of the
differences will focus on tax year 1987 as well as on 1981, since the latter was the last tax
year for which the 1983 report contained detailed estimates.
Table II-I highlights the four principal reasons why the new tax gap estimates are
lower than those published in 1983. These are: effects of recent tax legislation on individual

flit

~ndcorporatetax liabilities, .th~ availability.of new co~plianceand<?ther
data,improvements

I,

In methodology, and the OmISSIOn
of a remIttance gap In the new estimates.

'I

~1"

"I;

A. Shift of Tax Liabilities from Individuals to Corporations

"_:"

~

ji~
"

In 1986, the tax base was broadened by legislation that eliminated, restricted, and
phased out a number of subtractions from individual income. To the extent that, under new
law, a subtraction from income is no longer allowed, a taxpayer cannot overstate it on the tax
return. This reduces noncompliance. Moreover, becauserates at which individual incomes
are taxed were reduced, the tax gap associatedwith any given amount of unreported income
fell. (However, becausethe 60-percent deduction for capital gains income was repealed, the
capital gains tax gap increases.) As a consequence, recent legislation decreased the
individual income tax gap estimate for 1987 by $14.4 billion. This measuresthe direct impact
of the new law on the individual tax gap resulting from tax base broadening and lowered
marginal tax rates. No attempt was made to estimate the more subtle effects this

comprehensive
tax legislationmay haveon individual attitudesandreportingbehavior.
Despitea cut in thetop tax ratefrom 46 percentto 34 percent,corporatetax liabilities
increased. Therefore, our estimate of the corporate tax gap has been increased.
B. New Data
Both the 1981 and 1987 tax gap estimates of this report were affected by new data
that became available since the 1983 IRS report on the tax gap was published. New TCMP
data for tax year 1982 showed that fIlers of individual tax returns had not underreported their
incomes by as much as had been projected from earlier data. On the other hand, a new and

,

c--

Tax Gap Estimatesand Projections/or 1973-1992

Page 10

Table 11-1. Differences Between Old and New Gross Tax Gap Estimates for
Tax Years 1981 and 1987 by Reason for Change {in $ billions}
Total

Individuals

115.2

104.0

11.2

-7.6

-14.4

+6.82

New data

- 8.8

- 8.4

- 0.4

Improvedmethods

- 6.8

- 10.7

+3.9

-- 7.0

-- 7.0

--

Old

estimate

of

Legislative

legal

changes

sector

tax

gap 1

in tax liability

Omission of remittance gap
in the new estimate

Corporations

New

estimate

of

legal

sector

tax

gap 3

84.9

63.5

21.4

Old

estimate

of

legal

sector

tax

gap 1

81.5

75.3

6.2

New data

+0.7

- 4.3

+5.0

Improved methods

- 8.5

- 10.7

+2.2

Omission

of remittance

gap

..:...§&...:..2&.-=-

in the new estimate

New estimate

of legal sector tax gap 3

66.9

53.6

13.3

1 For the prior report, an additional partial tax gap estimate of $9.0 billion was prepared for the illegal sector.
The illegal sector tax gap was not estimated for this report.
2 Predicting the impact of recent legislation on corporation compliance is difficult.

We have no studies,

and little experience,to guide us in judging the effects of a major change in tax law. Therefore, we
assumedthat the corporate voluntary compliance rates (VCRs) for tax liability will remain constant. The
estimated tax gap rises becauseof the increasesin corporate tax liabilities. An alternative method would
assumeconstant voluntary reporting percentages(VRPs) for the elementsused to calculate net corporate
income (receipts, cost of goods sold, expenses). With this method, the effect would be to leave the
corporate tax gap estimate unchangedor to reduce it. This result would imply that VCRs would rise.
3 The estimatesof the legal sector tax gaps are on a recommendedbasis;
that is, they include some taxes that would be recommended,but which
ld
t be
d
al
wou
no
assesse
on appe.
assessed
basis are (in $ billions):

Th

e gross

tax

gap

.
estImates

on

an

1981

1987

Total
In . .
dlVlduals

5 7.0
47 6
.

71.2
56
.1

Corporations

9.4

15.1

Note: Details do not add due to rounding.

more elaborate IRS-sponsoredsurvey of expendituresin the informal economy for 1985
indicatedthat the comparablesurveyfor 1981had understatedinformal supplierincomes. The
scope of the previous study had omitted significant

transaction categories, including

informal

salesto businesses.New IRS-sponsoredstudiesof tipping practicesfor various periodsfrom
1979to 1985,togetherwith anotherIRS studyof tips reportedon Forms941 beforeandafter the

,

!

1

j

1_-

I

TaxGapEstimates
andProjectionsjor
1973-1992

Page11

new tip information reporting requirements mandated by TEFRA, led to reductions of the
estimate of tip-related tax gap. An IRS study of unreported capital gains for 1979 also led to
further reductions of the individual tax gap. For individuals, the combined impact of all these
new data sourceswas to lower the estimatesof the individual gap by $4.3 billion for 1981 and by
$8.4 billion for 1987.
For corporations, the major new data were from TCMP examinations of small
corporation tax returns essentially for 1980, new Statistics of Income (SOl) data, revised
Treasury projections of corporation tax liabilities, and operational examination results for Fiscal
Years 1984, 1985 and 1986. These taken together raised the corporation tax gap estimate by
$5.0 billion for 1981 and reduced it by $0.4 billion for 1987.

C. Improved Methods
For the individual tax gap, improvements in methods include new procedures for
expanding TCMP data to estimate the unreported income that was not detected in TCMP
audits, case-by-caseimputation of the additional unreported income not detected in TCMP
examinations to the TCMP data files for calculating the additional tax due, and a new analysis
of nonfiler data fIles (exact-match data) to estimate the nonfiler tax gap. These improvements
lowered the individual tax gap estimate for 1981 by $10.7 billion, and, by coincidence, the
corresponding estimate for 1987 also by $10.7 billion.
For the corporation estimates, new methods include the use of "yield curves" to
estimate tax gap not detected in operational examinations for corporations with assets
between $10 million and $100 million, and expansion of TCMP-detected unreported income
for corporations with less than $10 million in assets. These changes in tax gap estimation
methods raised the corporation tax gap estimate for 1981 by $2.2 billion and the
corresponding estimate for 1987 by $3.9 billion.
D. Remittance

t
I
i

Gap

The individual income tax gap estimated for the earlier report had two components:
the tax liability reporting gap and the tax remittance gap. The latter, in turn, consisted of two
component gaps. These were the sum of reported tax balancesdue which were not remitted
when individuals filed their tax returns, and the sum of employer underpayments of tax they
withheld from the wages of their employees. The remittance gap estimates of the previous
IRS report were not sufficiently accurate. Hopefully, we shall succeed in correcting this
situation in the near future. In the meantime, however, our revised estimates of the tax gap
exclude measuresof the remittance gap. Table ll-1 shows that the omission of the remittance
gap in the new estimates lowered the 1981 tax gap estimate by $6.8 billion and the 1987 tax
gap estimate by $7.0 billion.

.

Tax Gap Estimatesand Projectionsfor 1973-1992

Page 13

Chapter ill
Methodology

Tax noncompliance occurs either when a taxpayer does not file an obligatory return
or when a taxpayer files a return that does not accurately report the tax obligation incurred.
(Taxpayers may also fail to pay tax they report as due; estimatesof this "remittance gap" are
not included in this report.) Because these two forms of noncompliant behavior are quite
distinct, different sourcesof data and different estimation methods are necessaryto determine
the resulting tax loss to the government.
To estimate the noncompliance of filers, we examine a representative sample of the
returns that are filed to see whether the tax due has been accurately reported. Examiners,
however, cannot always find the incomes that are not reported on returns, particularly if
these incomes are earned "off the books." Consequently, special compliance studies and
surveys must supplement data from the examination of tax returns adequately to measure
some components of the tax gap. In the case of individual nonfilers, we work with a
public-use computer file of survey data from a representative sample of the general
population. Through exact matching of tax return records with the survey data, we estimate
the aggregateincome of individual taxpayerswho had not filed the required tax returns.
A. Filers

of Individual

Returns

The estimates of underreported income and overstated items of filers of tax returns
presented in this report are grounded in thorough IRS examinations of a representative
sample of such returns. These examinations are conducted every three years under IRS's
Taxpayer Compliance Measurement Program (TCMP). The TCMP surveys of individuals
are probability samples of approximately 50,000 tax returns. With appropriate "weighting,"
the TCMP data give us estimates of the aggregate error on each tax return line item that
would be found if all returns were examined.
Surveys basedon examinations generally disclose overstateddeductible items on tax
returns considerably better than they disclose understated income. This is because, to
disallow deductions, the examiner need only note the lack of adequatejustification or proof
for them. To recommend assessmentof tax on unreported income, however, the examiner
must locate evidence that the unreported income has in fact been received. Since it is
obviously more difficult to do the latter, the underreported incomes disclosed on TCMP
examinations are not adequatemeasuresof the actual income tax noncompliance of filers.
A study ofTY 1976 TCMP casesestimated the degree to which unreported incomes
covered by information returns (Forms W-2 or 1099, for example) were not disclosed on
TCMP examinations. This study provided a factual basis for raising the TCMP-derived
estimates to more accurate levels. Underreported incomes from all sources were not
expanded uniformly by the same multiplier. Cases in which underreporting occurred
because taxpayers made specific claims relating to the income that can be rebutted by an
examiner were distinguished from cases involving underreported receipts or other hidden
incomes that do not necessarily come to an examiner's attention during the course of an
audit. The former cases,in contrast, cover (overstated) offsets to business income or other
items that an examiner would normally not miss in auditing a taxpayer's return or books and

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I~-

Tax Gap Estimatesand Projectionsfor 1973-1992

Page 14

records. For example, taxpayers may understate royalty income by overstating their
depletion allowances, which examiners would readily discern. Another example is the case
of underreported capital gains income. This may occur because taxpayers overstate the
basis, understate the sales proceeds, miscalculate the gain, or fail to report the sale of an
asset. On a TCMP audit, in the absenceof information returns from third parties, the failure
to report the sale of an asset may never surface. However, in the case of a reported
transaction, the auditor normally will have accessto information to detennine whether the
reported capital gain has been understated due to overstating the basis or due to calculation
errors. In these instances, there is no need to expand with the aid of a multiplier the
unreported income to reflect more accurate levels. Special studies were conducted to help
determine what proportions of various types of underreportedincomes (such as capital gains,
royalties, dividends, and other income) should be expanded and what proportions should
not.
For every type of income, however, the expansion of the underreported income was
done in the aggregate fIrst. Then, the expanded underreported totals from each income
source were imputed to different records in the IRS research data base with the aid of a
computerized microdata tax model. This procedure made it possible to apply appropriate
marginal tax rates to the underreportedincomes from various sources.
Data from special IRS-sponsored sUIVeyswere used for tip income and net receipts
of informal suppliers. The data on tips (relating to various periods from 1979 to 1985) and
on informal suppliers (relating mainly to years 1981 and 1985) were extrapolated to the years
for which TCMP studies were conducted and imputed by the microdata model to individual
records for purposes of calculating tax gaps.
TCMP data from tax years 1973, 1976, 1979, and 1982 provide the basis for IRS
individual tax gap estimates. Data from SOl provided a basis for extending the compliance
estimatesthrough 1985-the last year for which SOl data are available.
We projected the tax gap and related compliance measures beyond 1985 in fouL
steps. First, we projected to 1992 voluntarily-reported income, deductions, and taxes paid
under pre-1986 law. We did this by combining forecasts from the Office of Management
and Budget and Wharton Econometrics. Second, assuming that VRPs for each tax return
line item remained constant at 1982 levels, we extended the estimatesof unreported incomes,
overstated deductions, and underreported taxes through 1992 on the assumption that
reporting for each tax return line item remained constant at the 1982 rates. Third, using a
computerized microdata tax model, we adjusted the projections to reflect the impact of new
tax law on each item reported. The new law lowered tax rates and made structural changesin
the tax base. These affect the composition of taxable income and, at constant item-by-item
compliance, the tax gap. For example, for 1987 through 1992, the proportion of gains on
salesof assetsrises becauseof the repeal of the 6O-percentcapital gains deduction, while the
proportion of non-mortgage personal interest falls.

.

Finally, provisions
we adjusted
projections to
reflect
the estimated
impacts
of
the compliance
ofthe
theestimates
Tax Actsand
of 1982-1986.
For
example,
we recognized
that

.

new information-reporting requirements would raise the amount of tips, capital gains, or
state tax refunds that are voluntarily reported, and that they would lower amounts
overreported for interest deductions or exemptions for dependents.

.-

I.

,

Tax Gap Estimatesand Projections/or 1973-1992

B. Individual

Page 15

Nonfilers of Returns

The estimationstartedwith an analysisof the public-usecomputerfiles from two
studies that matched data from a national household survey with data from the Social
Security Administration and IRS to estimate numbers and incomes of nonfilers of tax
returns. For calendar years 1972 and 1977, about 40,000 householdswere randomly
selected,forming a nationwide probability sample. Thus, the individuals and families
surveyedwere representativeof the entire U.S. populationregardlessof whetherthey had
receiveda Social Securitycard or whetherthey had filed a tax return with IRS. Individual
recordswere linked by identifiers-mainly Social Securitynumbers-to generatestatistical
information on nonfilers and their incomesfrom various sources. The data for the two
different yearswere adjustedto makethemcomparableandappropriatefor usein estimating
the nonfiler tax gap.
After the tax-relatedincomesof the nonfiler householdswere estimated,the records
of low-income householdswho would not be requiredto file were dropped. Next, the tax
consequences
of the remaininghouseholds'failing to report their incomeswere estimated.
This was doneby calculatingthe tax liabilities implied by the nonfiler incomesearnedwith
the useof the data basementionedabove. Estimatesof withholding and prepaymentwere
basedon SOl figures for the sameyears. Thesewere subtractedfrom the tax liability
estimatesto obtain the tax gap estimates. Projectionsfor other years were preparedby
relatingdataon nonftlersto theprojectionsfor comparablefilers for correspondingyears.

C. Corporations
Different methodswere usedto derive the tax gapsfor small corporationsand for
large corporations.For smallcorporations,TCMP surveydatawere availablefor estimating
the tax gap. For large corporations,operationalexaminationdata were used sinceTCMP
datawerenot available.
1. Small Corporations
The definition and methodof estimatingthe tax gap for small corporations(those
with assetsunder $10 million) are similar to thoseusedfor individuals. Both start with
TCMP datafor basiccompliancerateinformationon a recommendedbasisandboth convert
this to an assessed
basisto developan alternativeestimateof the final tax gap. Both alsouse
SOl asthe basisfor projectingthe TCMP results.
For years for which SOl tax data do not exist, projectionsfor small corporations
were basedon projectionsof total corporatetax liability madeby the Office of Tax Analysis
(OTA) of the TreasuryDepartment.Complianceratesfor small corporationswerebasedon
TCMP studies done mainly for tax years 1977 and 1980. For years after 1980, the
compliancerate was assumedto remainconstant We alsorecognizedthat it is not possible
to detect all of the underreportedincome of small businessentities. Unreportedincomes
disclosedon TCMP audits of small corporationswere expandedin a mannersimilar to the
expansionproceduresusedfor individuals.
To computethe tax gap on the expandedamountof unreportedincome, a tax rate
higher than the marginal tax rate from TCMP examinationswas used. Under a progressive
rate schedule,unreportedincomesnot disclosedby TCMP auditswould in someinstances
raisethe taxableincomesof smallercorporationsinto highertax brackets.

I

-

Tax Gap Estimatesand Projectionsfor 1973-1992

Page 16

For 1987 and later years, IRS adjusted the estimatesto account for the recent tax law
changes. The portion of the tax gap attributable to unreported income which TCMP does not
detect was reduced to allow for the reduction in marginal tax rates. The portion of the gap
attributed to the TCMP estimate of understatedtax was increased to allow for the net increase
in corporate income taxes on account of the rate reductions, base broadening, and accounting
rules. For this purpose, IRS used OTA's estimates of the increases in tax liabilities of
corporations due to the new tax law.
2. Large Corporations
As stated earlier, no TCMP exists for large corporations (those with assetsof $10
million or more). Consequently, we used data from regular examinations--either actual or
augmented with the aid of yield curves-to calculate the tax gap for large corporations. Tax
reported by these corporations was obtained from SOl and from OT A projections.
For corporations with assets of over $100 million, tax increases resulting from
actual examinations were used to calculate the tax gap. Although audit coverage for these
large corporations is about 86 percent, effective coverage may be close to 100 percent since
relatively little tax deficiency is thought to exist for the returns not examined.
For corporations with assetsof between $10 million and $50 million and between
$50 million and $100 million, IRS has estimated yield curves that show the averageexpected
audit yields at all levels of audit coverage. The estimates of audit yield at 100 percent audit
coverage were used to calculate the tax gap for corporations in these size classes.
For all large corporation classes, we averaged audit results or yield curves for the
three most recent years to estimate the compliance rate for reporting of tax liability. The
averaging eliminates the year-to-year variations due to administrative factors. The
compliance rates were computed separatelyfor each of three audit classesdefined in terms of
total assets: $10 million to $50 million; $50 million to $100 million; and $100 million and
over. The compliance rates were then applied to SOl estimates of reported tax liabilities for
i

i

each of the years 1973 through 1984, and to OTA estimates and projections for 1986 through
1992. For 1987-1992, the OTA projections included the expected additional reported tax

liabilities arising from enacted legislation. Since the principal reason for the increase in
corporate tax liabilities is the repeal of the investment tax credit, our assumption of a constant
compliance rate for reporting of tax liability implies a falling voluntary reporting percentage
for reporting of net income. We have no studies, and little experience, to guide us in judging
the effects of such a major change in tax law. Therefore, the estimates are particularly
subject to uncertainty.
For small corporations, we increased the TCMP-based tax gap estimates to reflect
unreported income not detected on examination. Since incomplete detection of unreported
income also occurs in operational examinations of large corporations, tax gap estimates for
large corporations may be understated.

3. "Other" Tax Gap
The "other" income tax gap estimate, which is included with the corporation gap
shown in Table 1-1, is composed of tax gap estimates for fiduciaries (the retained income of
trusts and estates) and for tax on the unrelated businessincome of tax-exempt organizations
(UBIT). The tax gap estimate for each of these two components is based on a TCMP study.
The resulting compliance rate in each case was applied to SOl and OT A estimates or
projections of tax liability for all years 1973 through 1992 to generate a tax gap estimate for
each year.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Airs%3Ae17a2404f0a4651c. Public record. Not legal advice.
