The IRS Issues Blank Check to Businesses

“The lack of money is the root of all evil.” Mark Twain

Since time immemorial humanity has confronted two inescapable fates: death, and taxes. The latter is particularly unavoidable for IRS employees like me who are required to pay their taxes by the due date (generally April 15th) or be terminated. Yes…it it both sadly ironic and perversely true that the very same people who make a living putting taxpayers on installment agreements (payment plans) must be separated from their employment with the IRS if they are unwilling or unable to pay their taxes by the due date. In addition to that employment perk, every IRS worker is audited back three tax filing years prior to being extended an offer of employment. Obviously, Congress did not exaggerate when they justified freezing the wages of federal employees for the third year in a row to prevent a government shutdown during sequestration by citing out of control federal pay and benefits. As I spend 40 hours a week listening to taxpayers conjure up every conceivable (and inconceivable!) deduction, or claim to a credit using every imaginable (and unimaginable!) justification, I frequently wonder if our country wouldn’t be more fiscally sound if every taxpayer were audited, or at least held to the same standards (professional, legal, and financial) as IRS employees.


Incredibly, many of America’s business owners have found a way to cheat taxation, if not death, by exploiting the attention that IRS employees place on customer service (like yours truly) rather than enforcing the tax laws that were written to fund the country. For instance, the IRS estimates that the annual net tax gap—the amount of taxes that go unidentified and uncollected each year—amounts to nearly $300 billion, a sum almost equal to 14 % of the entire amount of taxes IRS is required by law to collect. The Government Accountability Office (GAO), home to the federal government’s bean counters, so to speak, reported that federal contractors routinely abuse the tax system with little consequence by not remitting to the IRS payroll taxes that were withheld from salaries. The GAO audit discovered that more than 1.6 million businesses owed over $58 billion in unpaid federal payroll taxes, including interest and penalties. In addition, over 1,500 individuals were responsible for nonpayment of payroll taxes at three or more businesses, and 18 were responsible for not remitting payroll taxes for a dozen different businesses. In at least one of the GAO case study businesses, the IRS determined that the non-compliant business obtained contracts through its ability to undercut competitors due in part to the business’s reduced costs associated with its non-payment of payroll taxes. In other words, if left to accumulate unpaid payroll taxes, businesses gain an unfair business advantage over their competitors at the expense of taxpayers.


As of September 30, 2007, the latest year for which accurate figures are available, the IRS’s master file database of taxpayer accounts reflected about $282 billion in outstanding taxes owed by businesses and individuals. Additionally, the amount of unpaid taxes is understated because many tax debts go unidentified and unrecorded on IRS’s tax records due to non-filing or underreporting of tax liabilities. Therefore, the true cumulative amount of unpaid taxes would be far higher than $282 billion. Although IRS has powerful tools at its disposal to prevent the further accumulation of unpaid payroll taxes and to collect the taxes that are owed, IRS's current approach does not provide for their full, effective use. IRS's overall approach to collection focuses primarily on gaining voluntary compliance—even for egregious payroll tax offenders—a practice that can result in minimal or no actual collections for these offenders. Additionally, IRS has not always promptly filed liens against businesses to protect the government's interests and has not always taken timely action to hold responsible parties personally liable for unpaid payroll taxes. IRS is also not timely in assessing penalties to individuals responsible for not remitting business’s payroll tax debts.


The GAO audit also uncovered just what businesses are doing with all those unpaid payroll taxes: business owners or officers have diverted payroll tax funds for their own benefit or to help fund business operations. One example cited by the GAO was a dentist who had accumulated more than $500,000 over 10 years in unpaid payroll taxes. The dentist/owner put property in his spouse's name, and then sold property to his children for less than market value. Another example cited was that of a healthcare business that had accumulated over $8 million in unpaid payroll taxes for almost 30 quarters. Despite living in a multimillion dollar home, the taxpayer claimed inability to pay taxes due to financial hardship, and evaded IRS levies by using check cashing businesses and writing checks to himself, even paying himself a salary while incarcerated. Although other creditors seized and sold property to settle debts, the GAO found no evidence of the IRS taking such actions. Another example the GAO cited was that of an owner of a business that owed almost $2.5 million in taxes from under-reporting his personal income. Additionally, the owner was the subject of at least 10 lawsuits either pending or settled and was involved in possible check kiting and money laundering, and made large cash withdrawals prior to filing bankruptcy multiple times.


Unpaid payroll taxes include amounts owed for Social Security and Medicare and failing to pay those taxes creates a gap in the federal budget that requires the federal government to dip into the General Fund (the overall pool of tax dollars we pay) to cover the missing Social Security and Medicare taxes that businesses are failing to remit. The IRS estimates that the amount of unpaid taxes and interest attributable to Social Security and hospital insurance taxes is approximately $44 billion. Businesses with more than twenty quarters of tax debt (five years of unpaid payroll tax debt) more than doubled between 1998 and 2007. To add insult to injury, IRS is statutorily limited in the length of time it has to collect unpaid taxes—generally ten years from the date the tax debt is assessed, so the federal government will lose its right to collect billions of dollars in payroll taxes each year if IRS does not obtain payment from tax debtors before the statutory period for collection expires.


GAO also found that even though the IRS’s enforcement workload—measured by the number of tax returns filed—has continually increased, the number of staff dedicated to collections has not. In other words, if the IRS doesn’t hire more workers to go after deadbeat business owners and tax cheats, the government loses money and the compliant taxpayer bears an increased burden to fund the nation’s commitments. All federal employees have been under a pay freeze for two years and recent budget negotiations aimed at preventing a government shutdown resulted in legislation that froze the pay of IRS employees for a third straight year, in addition to mandating a hiring freeze and mandatory furloughs imposed by sequestration. Congress has apparently concluded that perpetual pay and hiring freezes, coupled with heavier workloads, is a recruiting incentive for those staffing government agencies like the IRS, which is responsible for collecting the taxes required to fund the government’s operations.


The failure of the IRS to collect the nation’s much needed revenue is not for want of legal resources to compel compliance. The GAO found that the IRS routinely fails to use certain collection tools like liens and levies against deadbeat companies, yet the IRS goes after grandmothers and seizes family homes to satisfy personal tax debts. The GAO’s audit of businesses found that IRS revenue officers continued to work with businesses to gain voluntary compliance while the business continued to accumulate unpaid payroll taxes. In its 2000 study, the law enforcement arm of IRS, TIGTA (Treasury Inspector General for Tax Administration), found that revenue officers were entirely focused on the IRS’s customer service goals and therefore were reluctant to take enforcement actions. As a result, they continued to work with tax debtors to gain voluntary payment rather than using more aggressive enforcement tools such as levies or seizures. TIGTA also reported that as a result of IRS not taking effective collection actions, the cases accrued more unpaid taxes while assigned to revenue officers than the revenue officers were able to collect. IRS officials admitted to the GAO that finding an account with money in it is often a “hit or miss” proposition since they are one-time levies and a levy is served against an account, a tax debtor will often close the account and open an account in a different financial institution. For example, one business had tax debt from 2000, but IRS did not assess a penalty against the business’s owner until the end of 2004. In the meantime, the owner was drawing an annual salary of about $300,000 and had sold property valued at over $800,000. Within 1 month of IRS assessing the penalty, the owner closed the business, which by then had accumulated about $3 million in unpaid taxes.


The GAO concluded its audit of IRS collection procedures by observing that allowing businesses to continually fail to remit payroll taxes negatively impacts the general public’s perception regarding the fairness of the tax system, and found that IRS’s failure to punish businesses that continually accumulate unpaid payroll taxes has the effect of subsidizing their business operations, thus enriching tax abusers or prolonging the demise of a failing business. Perhaps this is why so many Americans believe that paying taxes is a discretionary matter that can be easily bypassed using an exception (i.e. deduction, exemption, or credit) granted by Congress. If so, my salary and benefits are well justified, but only at the expense of American taxpayers who bear a growing share of the tax responsibilities of businesses and citizens who enjoy all the privileges of membership in Club Citizenship but shrink from the duty of paying their membership dues.

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