The
Small Business/Self-Employed Division Is Beginning to Address Challenges That Affect
Corporate Return Examination Coverage
August 2005
Reference Number: 2005-30-130
This report has cleared the Treasury Inspector General for Tax Administration disclosure review process and information determined to be restricted from public release has been redacted from this document.
Phone Number |
202-927-7037
Email Address | Luis.Garcia@tigta.treas.gov
Web Site
| http://www.tigta.gov
August 22, 2005
MEMORANDUM FOR COMMISSIONER, SMALL BUSINESS/SELF-EMPLOYED DIVISION
FROM: Pamela J. Gardiner /s/ Pamela J. Gardiner
Deputy Inspector General for Audit
SUBJECT: Final Audit Report – The Small Business/Self-Employed Division Is Beginning to Address Challenges That Affect Corporate Return Examination Coverage (Audit # 200430030)
This report presents the results of our review of statistical information that reflects Examination function activities in the Small Business/Self Employed (SB/SE) Division. The overall objective of this review was to analyze statistical data on closed small corporation and S corporation[1] return examinations for Fiscal Years (FY) 2001 through 2004 in the SB/SE Division to identify and report trends.
Synopsis
The Internal Revenue
Service (IRS) views the examination of income tax returns as an important tool
to encourage voluntary compliance. One
measure of the IRS’ overall Examination program is the “examination coverage
rate,” commonly known as the “audit rate,” which is computed by dividing the
number of tax returns examined by the total number of tax returns filed in the
previous calendar year.[2]
In summary, the
number of small corporation and S corporation returns examined from FY 2001 to
FY 2004 decreased, but recent Examination program initiatives may reverse this
trend. Specifically, in Calendar Year 2003,
small corporations filed approximately 2.3 million U.S. Corporation Income Tax
Returns (Form 1120) and S corporations filed approximately 3.4 million U.S
Income Tax Returns for an S Corporation (Form 1120S) with the IRS. The audit rate for small corporations was .32
percent and for S corporations was .19 percent in FY 2004.[3] The
IRS Commissioner has commented on the decreased examination coverage in this
area and that he expected audits to increase in 2005.
This audit focused
on examinations of small corporations and S corporations with less than $10
million in assets closed by the SB/SE Division during FYs 2001 through
2004. Our analysis showed the number of
small corporation and S corporation examinations significantly declined during
this period, from 19,339 to 7,328 (approximately 62 percent). Moreover, acute declines in the number of
examinations closed occurred from FY 2003 to FY 2004 when workload shifts
caused a decreased emphasis on small corporation and S corporation examinations. The number of small corporation examinations
decreased by 46 percent, while the number of S corporation examinations decreased
by 57 percent. The decline in the number
of FY 2004 small corporation examinations closed resulted in a 23 percent
decrease in dollars recommended[4] from FY 2003 ($188 million) to FY 2004 ($145
million). Conversely, the average recommended
assessment dollars per return for small corporations showed a positive trend,
going from approximately $23,500 in FY 2003 to approximately $33,370 in FY
2004.
However, approximately
43 percent of small corporation returns examined had no change to the tax
reported on their returns for FYs 2001 through 2004. The IRS segregates these “no-change” returns
into those with adjustments and those without adjustments. For FYs 2001 through 2004, approximately 30
percent of the no-change returns had adjustments. During this same period, approximately 366
Direct Compliance Years[5] were charged to small corporation returns
with no changes. For S corporations, 42
percent of the returns examined resulted in no changes; these examinations accounted
for 286 Direct Compliance Years during FYs 2001 to 2004. During discussions with IRS management, the
IRS commented on the value of return examinations closed with adjustments but
no change to the tax reported. For small
corporations, such examinations may include noncompliant taxpayers but due to
offsets, such as net operating losses or credit carryovers, no additional tax
is due in the year under examination.
For S corporations, a no-change examination could result in an
adjustment on other related returns, such as the shareholder’s individual
return.
Case selection
systems, such as the Discriminant Index Function (DIF),[6] do not meet current Examination program
needs. The DIF formulas used to score
returns have not been updated since the 1980s and do not identify current IRS
key compliance strategy cases such as abusive schemes, unreported income, and
structured transactions. The focus for
the FY 2004 Examination program was on key strategies the DIF could not address;
therefore, examinations of small corporation and S corporation returns that
were not a part of the strategies were not a priority. In FY 2004, the SB/SE Division selected 22
percent of small corporation returns using the DIF; the other 78 percent were
selected from non-DIF sources.
The SB/SE Division
recognizes the need to improve the selection of tax returns for examination and
has initiatives underway, such as the Compliance Initiative Projects (CIP) that
focus on identifying potential areas of noncompliance and developing strategies
to improve compliance. Some CIP-identified
returns entered the audit stream in October 2004, and examination results are
pending. The SB/SE Division has also
taken steps to address its longstanding human capital crisis by authorizing the
hiring of 984 revenue agents in FY 2005.
However, the full contribution of these new hires on helping reverse the
decline in small corporation examinations will not be realized for several
years. Also, the burden on existing
staff in providing training and guidance to the new staff may further hamper productivity.
Overall, during this
audit, there was insufficient evidence to evaluate whether recent management
actions will be effective in reversing the decline in the number of
examinations, but we will continue to monitor their implementation and resulting
effects.
Response
We made no
recommendations in this report. However,
key IRS management officials reviewed it prior to issuance.
Copies of this report are also being sent to the IRS managers affected by the report findings. Please contact me at (202) 622-6510 if you have questions or Curtis Hagan, Assistant Inspector General for Audit (Small Business and Corporate Programs), at (202) 622-3837.
Examinations
Recommending No Changes Remain Constant
Initiatives Are
Underway to Address Return Selection and Increase Resources for Examinations
Appendices
Appendix
I – Detailed Objective, Scope, and Methodology
Appendix
II – Major Contributors to This Report
Appendix
III – Report Distribution List
Appendix
IV – Detailed Charts of Statistical Information
The Internal Revenue Service (IRS) views the examination of income tax returns as an important tool to encourage voluntary compliance. One measure of the IRS’ overall Examination program is the “examination coverage rate.” Commonly known as the “audit rate,” it is computed by dividing the number of tax returns examined by the total number of tax returns filed in the previous calendar year.[7]
An April 2004 article from The Wall Street Journal, “IRS Audits of Corporations Continued to Decline in 2003,” reported, “IRS audits of corporations continue to drop, despite a recent turn around in enforcement against individual taxpayers, said a report by Transactional Records Access Clearinghouse, a government watchdog group. Overall, face-to-face audits of all corporations declined to 7% in 2003 from 15% in 1999.”[8]
In Calendar Year 2003,
small corporations filed
approximately 2.3 million U.S. Corporation Income Tax Returns (Form 1120) and S
corporations filed approximately 3.4 million U.S. Income Tax Returns for an S
Corporation (Form 1120S)[9] with the IRS. The audit rate for small corporations was .32
percent in Fiscal Year (FY) 2004 compared to .60 percent in FY 2001. For S corporations, the audit rate was .19
percent in FY 2004 compared to .43 percent in FY 2001.[10] The
IRS Commissioner has commented on the decreased examination coverage in this
area and that he expected audits to increase in 2005.
The IRS Small Business/Self-Employed (SB/SE) Division serves about 7 million small businesses, including corporations, S corporations, and partnerships with less than $10 million in assets. This audit focused on examinations of small corporations and S corporations closed by the SB/SE Division during FYs 2001 through 2004.
Small business
compliance is important to tax administration.
Approximately 68 percent ($141 billion) of the estimated $207 billion
tax gap in 1998 was attributed to SB/SE Division taxpayers. Sole proprietors accounted for about $132.5
billion of this gap, and corporate taxpayers were responsible for $8.3
billion. These tax gap estimates were
updated in 2005 to between $312 and $353 billion, and the FY 2004 - 2005
Compliance Risk Assessment[11] revealed that those areas of noncompliance
associated with the tax gap (i.e., nonfiling, nonpayment, and underreporting) continue
to widen.
This review was performed at the SB/SE Division Headquarters Office in New Carrollton, Maryland, in the Office of Examination Planning and Delivery during the period September 2004 through June 2005. The audit was conducted in accordance with Government Auditing Standards. Detailed information on our audit objective, scope, and methodology is presented in Appendix I. Major contributors to the report are listed in Appendix II.
The mission of the IRS is to provide
In May 2003 testimony to the Congress, the Government Accountability Office (GAO) stated, “Taxpayers’ willingness to voluntarily comply with the tax laws depends in part on their confidence that their friends, neighbors, and business competitors are paying their fair share of taxes. The IRS’s compliance programs, including audits and other efforts, are viewed by many as critical to maintaining the public’s confidence in our tax system.”[13]
Analyses of IRS examination data[14] from
FYs 2001 through 2004 showed a sharp decline in the number of small corporation
and S corporation returns examined and closed by the SB/SE Division. The number of Form 1120 and 1120S
examinations closed decreased from 19,339 to 7,328 (approximately 62 percent)
from FYs 2001 to 2004. Specifically,
Form 1120 examinations decreased from 10,686 to 4,353 (approximately 59
percent) and Form 1120S examinations decreased from 8,653 to 2,975
(approximately 66 percent). Moreover,
acute declines in the numbers of examinations closed occurred from FY 2003 to
FY 2004. The number of Form 1120
examinations closed dropped from 7,996 to 4,353 (approximately 46 percent),
while the number of Form 1120S examinations closed dropped from 6,884 to 2,975
(approximately 57 percent).
Figure 1 shows the decline in Forms 1120 and 1120S examined
from FYs 2001 through 2004 by the SB/SE Division.
Figure 1: Forms 1120 and 1120S Examined – Assets Under
$10 Million
Figure 1 was removed due to its size. To see Figure 1, please go to the Adobe PDF
version of the report on the TIGTA Public Web Page.
The decline in the number of returns examined resulted in a
corresponding decrease in dollars recommended.[15]
Figure 2 shows that the decline in the number of FY 2004 Form 1120 examinations
closed resulted in a 23 percent decrease in dollars recommended from FY 2003 ($188
million) to FY 2004 ($145 million).
Figure 2: Dollars
Recommended – Forms 1120
Figure 2 was removed due to its size. To see Figure 2, please go to the Adobe PDF version
of the report on the TIGTA Public Web Page.
Although
there was a significant decrease in the total dollars recommended from FY 2003
to FY 2004, the average dollars per return for Forms 1120 actually increased. Figure 3 shows the average dollars per return
increased from $23,512 in FY 2003 to $33,377 in FY 2004.
Figure 3: Average Dollars Per Return – Forms 1120
Figure 3 was removed due to its size. To see Figure 3, please go to the Adobe PDF
version of the report on the TIGTA Public Web Page.
Most of the SB/SE Division examinations in FY 2004 were
based on key strategies rather than on selection methods, such as the
Discriminant Index Function (DIF)[16]
or activity code.[17] According to the SB/SE Division, the
compliance strategic initiatives, workload priorities, and major operational
priorities for FY 2004 were:
The above initiatives exclude many small corporation and S corporation returns from the examination process. Focusing the majority of resources on the initiatives leaves an entire segment of taxpayers out of the IRS enforcement program. In a December 30, 2003, article from AccountingWEB.com,[18] IRS officials concede that their agency is simply not a factor for businesses in deciding whether to follow the Internal Revenue Code.
In a previously issued report,[19]
we determined the number of examinations of small corporation returns in FY
2003 continued the decrease that started in FY 1997. The IRS attributed the decrease in part to a
reallocation of resources. More recently,
on January 5, 2005, the IRS Commissioner pointed to some increases in
enforcement statistics but noted that one
compliance area to keep an eye on might be small businesses, companies with
less than $10 million in assets. Despite
the overall gains in corporate return examination coverage, the audit rate for
small businesses fell from .58 percent in 2003 to .32 percent (a 45 percent
decrease) in 2004. The IRS Commissioner
attributed the 2004 decrease to many factors, including diverting resources to
enforcement of compliance of wealthy taxpayers and to investigations of abusive
tax shelters.[20]
The SB/SE Division faced a number of challenges and changes
during our audit period. Several factors
resulted in a decline in the numbers of small corporation and S corporation returns
examined and examinations closed, including major organizational realignments,
budgetary constraints, and increased customer service and reengineering
efforts. Additionally, workload shifts
to examinations of abusive tax schemes, flow-through entities, off-shore trusts,
and high-income taxpayers caused a decreased emphasis on corporations with less
than $10 million in assets.
Examinations Recommending No Changes Remain
Constant
The IRS examines
income tax returns to determine whether corporations and other taxpayers have
voluntarily complied with tax laws and reported the proper amount of tax. To use its resources efficiently, the SB/SE
Division attempts to identify and examine returns with the greatest likelihood
of noncompliance. Examinations that
result in no change to the tax reported deplete limited resources and burden
compliant taxpayers who voluntarily reported the correct amount of tax.
IRS return selection
processes have not been effective in decreasing the number of examinations that
result in no change to the tax reported.
During FYs 2001 through 2004, approximately 43 percent of small
corporation returns examined resulted in no change to the tax reported. Returns examined and closed with no change to
the tax reported are referred to as “no-change” returns.
The IRS further
segregates no-change returns into two categories: (1) returns for which the IRS recommends an
adjustment to the taxpayer’s return but ultimately the tax reported does not
change and (2) returns for which there were no adjustments to the return and
the IRS accepts the return as originally filed by the taxpayer. Figure 4 shows that the overall percentage of
no-change returns for Forms 1120 has slightly decreased from FYs 2001 through
2004 but still remains over 40 percent. The
table also shows that of the total number of no-change returns examined
(14,468), approximately 30 percent (4,279) resulted in adjustments to
taxpayers’ returns, but with no change in the tax reported.
Figure 4:
No-Change Returns for FYs 2001 – 2004
|
|
FY 2001 |
FY 2002 |
FY 2003 |
FY 2004 |
TOTALS |
|
Returns[21]
Examined |
10,686 |
11,005 |
7,996 |
4,353 |
34,040 |
|
No-change
Code 01[22] |
1,365 |
1,186 |
1,090 |
638 |
4,279 |
|
No-change
Code 02[23] |
3,302 |
3,443 |
2,266 |
1,178 |
10,189 |
|
% of
No-change Code 01 |
12.77 |
10.78 |
13.63 |
14.66 |
12.57 |
|
% of
No-change Code 02 |
30.90 |
31.29 |
28.34 |
27.06 |
29.93 |
|
%Total No-change Codes 01 & 02 |
43.67 |
42.06 |
41.97 |
41.72 |
42.50 |
Source: TIGTA analysis of AIMS data for FYs 2001 -
2004.
For Forms 1120S, approximately 42 percent of returns
examined were no-change returns for FYs 2001 through 2004. Of the
total number of Form 1120S returns examined and categorized as no-change
returns (11,529), approximately 11 percent (1,317) were no-change returns with
adjustments. During this same period,
approximately 366[24] (36 percent) of the total Direct Compliance
Years[25] (1,018) applied to Form 1120 examinations
were charged to no-change returns. Approximately
286[26] (38 percent) of the total Direct Compliance
Years (759) applied to Form 1120S examinations were expended on no-change
returns.
During discussions
with IRS management concerning the issues in this report, the IRS commented
that small corporation examinations closed as no-change with adjustments may
include noncompliant taxpayers. However,
offsets such as net operating losses or credit carryovers may result in no
additional tax in the year under examination.
In addition, IRS management also stated that no-change examinations of
an S corporation return could result in an adjustment on other related returns,
such as the shareholder’s individual return, since the Form 1120S is a pass
through return. Therefore, the no-change
with adjustment examinations do differ from complete no-change examinations.
We agree that
no-change with adjustment cases do have value.
However, the number of no-change returns is one indicator the SB/SE
Division examination workload identification and selection systems and
processes are not adequately identifying tax returns with the greatest yield
potential. One challenge of new workload
identification and selection techniques is developing sufficient, up-to-date
technical expertise.[27]
Without improved identification and selection, the SB/SE Division runs
the risk of expending excessive resources on less egregious noncompliant
taxpayers and negatively affecting customer service with unnecessary taxpayer
contacts.
Our review and analysis
of a judgmental sample of 24 small corporation return examinations closed with no
changes to the tax reported in FY 2004 determined that, overall, the 24 examination
files contained sufficient documentation to explain the total cycle days[28] and examiner time. The 24 sampled examinations each had total
cycle days exceeding 900 and examiner time below 50 hours. These examinations were reviewed to determine
whether documentation existed to support the decision to close the examinations
with no changes to the tax reported.
Initiatives Are Underway to Address Return
Selection and Increase Resources for Examinations
The IRS is concerned about declines in the examination coverage of small corporations and S corporations and the productivity of tax returns selected for examination. The SB/SE Division has initiatives underway to improve return selection and increase resources to examine returns.
The SB/SE Division
uses Compliance Initiative Projects (CIP) to improve return selection
The SB/SE Division
recognizes the need to improve the selection of returns for examination because
case selection systems such as the DIF do not meet current needs. The DIF is based on assumptions developed
after completion of the 1988 Taxpayer Compliance Measurement Program (TCMP)[29] and has not been updated. The DIF was not designed to score tax returns
based on the IRS’ current key enforcement strategies, such as abusive schemes,
unreported income, and structured transactions.
Since the focus of the FY 2004 Examination program was on key strategies
the DIF could not address, examinations of small corporation and S corporation
returns that were not a part of those strategies were not a priority.
In FY 2004, the
SB/SE Division selected 22 percent of small corporation returns using the DIF;
the other 78 percent were selected from non-DIF sources.
[30] While
the DIF-selected returns accounted for just 22 percent of the FY 2004
examinations, the DIF scoring system was reasonably effective. Recommended dollars from the DIF-scored
examinations were comparable to those from non-DIF examinations. The DIF-selected returns contributed 32
percent of the recommended dollars.
Additionally, DIF-selected returns resulted in a lower number of
no-change returns.[31]
To assist in the return selection process, the IRS has
implemented the use of CIPs to identify returns with better audit potential
than those currently being selected using the DIF. The CIPs focus on identifying potential areas of noncompliance and developing
strategies to improve compliance. Some
CIP-identified returns entered the audit stream in October 2004, and
examination results are pending.
Increased Examination program
staffing should eventually help to increase the examination coverage of small
corporation and S corporation returns
The
SB/SE Division, as well as the rest of the IRS, continues to face a human
capital resource crisis. From FYs 2001 through
2004, 853 SB/SE Division employees transferred to the Large and Mid-Size
Business (LMSB) Division. Furthermore, 25
percent of the SB/SE Division revenue agents will be eligible for retirement by
the end of FY 2005; 36 percent of the SB/SE Division workforce will be eligible
for retirement by the end of FY 2006.
The following represents revenue agents that transferred from the SB/SE
Division to the LMSB Division according to IRS personnel data:
·
FY 2001 – 379.
·
FY 2002 – 81.
·
FY 2003 – 119.
·
FY 2004 – 274.
To reverse the decline in compliance resources, the SB/SE Division was authorized to hire 984 revenue agents in FY 2005 as part of its Curb Egregious Noncompliance initiative. This initiative is one of the SB/SE Division’s major FY 2005 goals. Through this initiative, the SB/SE Division seeks to reverse the continuing decline in compliance resources and to maintain the public’s faith in the fairness of our nation’s tax system.
Although the IRS appears committed to increasing SB/SE
Division compliance resources, it will likely take several years to see the
effect on increasing the number of small corporation and S corporation return examinations. It is uncertain whether increased resources will
guarantee a solution to the declining examination coverage. Also,
the burden on existing staff to provide training[32] and guidance to the new staff may further
hamper productivity.
The IRS’ efforts are
encouraging, but it is too soon to determine the impact on small corporation
and S corporation examinations
While we are
encouraged by the IRS’ efforts to develop better return selection methods
through the CIPs and to increase enforcement staffing, it is unclear how
effective management’s actions will be in reversing the declining examination
coverage trend and reducing the number of examinations resulting in no changes
to tax reported, especially in the near future.
In our opinion, the voluntary compliance of small corporations and S
corporations may be negatively affected with the continuing decline in the
number of examinations.
Continued efforts to
increase the examination coverage are important to the effectiveness of the
voluntary compliance system. During this
audit, there was insufficient evidence to evaluate whether recent management
actions will be effective in reversing the decline in the number of examinations. We plan to monitor their implementation and
resulting effects in future TIGTA audits.
We have no specific recommendations to offer at this time.
Appendix I
Detailed Objective,
Scope, and Methodology
The overall objective of this review was to analyze statistical data on closed small corporation and S corporation[33] return examinations for Fiscal Years (FY) 2001 through 2004 in the Small Business/Self-Employed (SB/SE) Division to identify and report trends. To meet our objective, we relied on the Internal Revenue Service’s (IRS) internal management reports and databases. We did only limited testing to establish the reliability of these data because extensive data validation tests were outside the scope of the audit and would have required a significant amount of time. To accomplish our objective, we:
I. Reviewed the mission statements, centralized workload plans, and strategic planning initiatives of the SB/SE Division with respect to enforcement and examination coverage for the corporate Examination program.
A. Determined the focus for the corporate Examination program and whether return closure is the program’s emphasis.
B. Determined whether the SB/SE Division has a sufficient number of trained examiners to meet program goals and objectives.
II. Analyzed data on the closed Audit Information Management System (AIMS)[34] database to identify the numbers and types of small corporation and S corporation return examinations conducted for FYs 2001 through 2004. Analyses included determining the number of closed examinations for each period, average dollars per return, average hours per return, and average assessments by disposal code. We also analyzed the number of returns selected by source and activity code.[35] Based on the analyses conducted in this test, we attempted to identify trends in the corporate Examination program.
A. Determined what disposal codes count as a return closure.
B. Evaluated the return closure disposal codes that resulted in no change to the tax reported. We determined the time open and the time charged to disposal codes that resulted in no change to the tax reported for examinations that were not completed.
1. Selected a judgmental sample of 30[36] cases for which total cycle days[37] exceeded 900 days and examiner time charges were below 50 hours. A judgmental sample was used due to time constraints. We reviewed the closed examination files to determine whether documentation existed to support no change to the tax reported. We selected this sample from a population of 4,353 small corporation returns examined and closed by the SB/SE Division in FY 2004 on the AIMS database. Of the 4,353 closed returns, there were 1,816 closed with no change to the tax reported.
III. Based on identified trends, discussed plans to have the SB/SE Division corporate Discriminant Index Function (DIF)[38] Examination program provide more balanced examination coverage.
A. Interviewed management to determine plans for increasing examination coverage in the SB/SE Division corporate Examination program.
B. Secured and reviewed plans, meeting minutes, and other documents that pertain to the future of the SB/SE Division corporate Examination program.
C. Reviewed documents pertaining to the staffing changes and staff years specific to the SB/SE Division corporate Examination program for FYs 2001 through 2004.
D. Assessed the resources allocated to the corporate Examination program.
Appendix II
Major Contributors
to This Report
Curtis
W. Hagan, Assistant Inspector General for Audit (Small Business and Corporate
Programs)
Richard
J. Dagliolo, Director
Philip
Shropshire, Director
Timothy
F. Greiner, Acting Audit Manager
Michael
A. Howard, Acting Audit manager
Cynthia
Dozier, Lead Auditor
Lisa
M. Stoy, Senior Auditor
Roy
E. Thompson, Senior Auditor
Appendix III
Commissioner
C
Office of the Commissioner – Attn: Chief of Staff C
Deputy Commissioner for Services and
Enforcement SE
Deputy Commissioner, Small
Business/Self-Employed Division SE:S
Director, Examination SE:S:E
Director, Examination Planning and
Delivery SE:S:E:EPD
Chief Counsel
CC
National Taxpayer Advocate TA
Director, Office of Legislative Affairs CL:LA
Director, Office of Program Evaluation and Risk Analysis RAS:O
Office of Management Controls OS:CFO:AR:M
Audit Liaison: Commissioner, Small Business/Self-Employed
Division SE:S
Appendix IV
Detailed Charts of Statistical Information
As shown in Figure 1,
the sources of U.S. Corporation Income Tax Returns (Form 1120) selected for
examination have changed dramatically since Fiscal Year (FY) 2001, with fewer
returns selected from the Discriminant Index Function (DIF)[39] scoring system being examined in recent years.
Figure
1: Sources of Small Corporation Returns
Examined
for FYs 2001 - 2004
Figure 1 was removed due to its size. To see Figure 1, please go to the Adobe PDF
version of the report on the TIGTA Public Web Page.
As shown in Figure 2, overall, DIF-selected returns had fewer
returns closed with no changes.
Figure
2: Percentage of Returns Examined With
No Change to Tax Reported, Based on Source of Selection
|
|
FY 2001 |
FY 2002 |
FY 2003 |
FY 2004 |
|
DIF and DIF-Related Returns: |
|
|
|
|
|
No changes, adjustment |
7.03% |
6.67% |
8.65% |
12.11% |
|
No changes, no
adjustment |
31.94% |
31.82% |
28.39% |
13.71% |
|
Total |
38.97% |
38.49% |
37.04% |
25.82% |
|
Non-DIF Returns: |
|
|
|
|
|
No changes, adjustment |
18.96% |
16.67% |
20.38% |
15.36% |
|
No changes, no
adjustment |
29.77% |
30.53% |
28.28% |
30.74% |
|
Total |
48.73% |
47.20% |
48.66% |
46.10% |
Source: TIGTA analysis
of AIMS data for Forms 1120.
As shown in
Figure 3, the numbers of training returns examined (Forms 1120 and U.S. Income
Tax Returns for an S Corporation [Form1120S]) increased from 151 in FY 2001 to
2,459 in FY 2004.
Figure
3: Changes in the Number of Training
Return Examinations by Fiscal Year
Figure 3 was removed due to its size. To see Figure 3, please go to the Adobe PDF
version of the report on the TIGTA Public Web Page.
As shown in Figure 4, the numbers of examiner hours expended on training returns (Forms 1120 and 1120S) have increased sharply since FY 2001, as new revenue agents have been hired.
Figure
4: Examination Program Resources
Dedicated to Training Returns
Figure 4 was removed due to its size. To see Figure 4, please go to the Adobe PDF
version of the report on the TIGTA Public Web Page.
[1] S corporations are corporations that elect to pass corporate income and losses to their shareholders for Federal tax purposes.
[2] Management Advisory Report: The Internal Revenue Service’s Response to the Falling Level of Income Tax Examinations and Its Potential Impact on Voluntary Compliance (Reference Number 2002-30-092, dated June 2002).
[3] The audit rates from the FY 2004 IRS Data Book include both Forms 1120 and 1120S examined by the SB/SE and Large and Mid-Size Business Divisions. The audit rates include training returns and returns examined by correspondence.
[4] Dollars recommended represents the amount of additional tax proposed to be assessed against the taxpayer.
[5] Based on
a Direct Compliance Year composed of 2,000 hours of Direct Examination Time.
[6] The DIF is a mathematical technique used to classify income tax returns as to Examination program potential.
[7] Management Advisory Report: The Internal Revenue Service’s Response to the Falling Level of Income Tax Examinations and Its Potential Impact on Voluntary Compliance (Reference Number 2002-30-092, dated June 2002).
[8] Mckinnon, John D. 2004. “IRS Audits of Corporations Continued to Decline in 2003.” The Wall Street Journal. April 12.
[9] S corporations are corporations that elect to pass corporate income and losses to their shareholders for Federal tax purposes.
[10] The audit rates from the FY 2004 IRS Data Book include both Forms 1120 and 1120S examined by the Small Business/Self-Employed and Large and Mid-Size Business Divisions. The audit rates include training returns and returns examined by correspondence.
[11] Compliance Risk Assessments are part of the IRS’ overall strategic assessment; each operating division was required to prepare an analysis and assessment of the compliance risk for each taxpayer segment.
[12] “IRS Simplifying Business Tax Audits.” AccountingWEB.com. December 30, 2003.
[13] Compliance and Collection: Challenges for IRS in Reversing Trends and Implementing New Initiatives (GAO-03-732T, dated May 7, 2003).
[14] We analyzed data from the IRS Audit Information Management System (AIMS). The AIMS is a computer system used to control returns, input assessments/adjustments to the Master File, and provide management reports. The Master File is the IRS database that stores various types of taxpayer account information. This database includes individual, business, and employee plans and exempt organization data.
[15] Dollars recommended represents the amount of additional tax proposed to be assessed against the taxpayer.
[16] The DIF is a mathematical technique used to classify income tax returns as to Examination program potential.
[17] An activity code is a three-digit numeric code that identifies the type and condition of a return selected for audit.
[18] “IRS Simplifying Business Tax Audits.” AccountingWEB.com. December 30, 2003.
[19] Trends in Compliance Activities Through Fiscal Year 2003 (Reference Number 2004-30-083, dated April 2004).
[20]
[21] Our populations include all Forms 1120 for small corporations (those with assets of less than $10 million) examined by revenue agents in the SB/SE Division. Training returns are not included in the populations.
[22] Code 01 identifies returns with an adjustment but no change in tax reported.
[23] Code 02 identifies returns with no adjustments and no change in tax reported.
[24] The 366 includes no-change returns with adjustments (99) and no-change returns without adjustments (267).
[25] Based on a Direct Compliance Year composed of 2,000 hours of Direct Examination Time.
[26] The 286 includes no-change returns with adjustments (24) and no-change returns without adjustments (262).
[27] Small Business/Self-Employed Strategic Assessment Report for FY 2003 and 2004 (March 1, 2002, issued by the IRS).
[28] Total cycle days are the number of days from when the return is filed until the examination process is completed.
[29] The TCMP used lengthy and detailed examinations to comprehensively measure taxpayer compliance and identify potential tax law changes.
[30] See Appendix IV, Figure 1.
[31] See Appendix IV, Figure 2.
[32] See Appendix IV, Figures 3 and 4.
[33] S corporations are corporations that elect to pass corporate income and losses to their shareholders for Federal tax purposes. Small corporations file U.S. Corporation Income Tax Returns (Form 1120); S corporations file U.S Income Tax Returns for an S Corporation (Form 1120S).
[34] The AIMS is a computer system used to control returns, input assessments/adjustments to the Master File, and provide management reports. The Master File is the IRS database that stores various types of taxpayer account information. This database includes individual, business, and employee plans and exempt organization data.
[35] An activity code is a three-digit numeric code that identifies the type and condition of a return selected for audit.
[36] The sample size was adjusted to 24 because 6 returns were considered Large and Mid-Size Business Division returns.
[37] Total cycle days are the number of days from when the return is filed until the examination process is completed.
[38] The DIF is a mathematical technique used to classify income tax returns as to Examination program potential.
[39] The DIF is a mathematical technique used to classify income tax returns as to Examination program potential.