____________________________________________________________________________
___
Title: Internal Revenue Service Receivables
Subtitle:
Report No.: GAO/HR-93-13 Date: December 1992
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Author: United States General Accounting Office
Addressee: High-Risk Series
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Overview
- The Problem
- The Causes
- GAO's Suggestions for Improvement
IRS Collections
Billions of Dollars Uncollected
Lack of Information
- How Many Accounts Are Valid
- Which Accounts Are Valid
- Which Tools Work Best
Inefficient Collection Process
Balancing Collection Efforts With Taxpayer Protection
Decentralized Organizational Structure
Uneven Staffing
Conclusions and Action Needed
Related GAO Products
High-Risk Series
- Lending and Insuring Issues
- Contracting Issues
- Accountability Issues
Figures
=======
Figure 1: IRS' Delinquent Tax Collections and Accounts Receivable Trends,
Fiscal Years 1988 to 1991
Figure 2: District Office Staff Collections Compared to Dollars Added to
Currently Not Collectible Status, Fiscal Years 1987 to 1991
Figure 3: Percent Change in Revenue Officer Case Closures per Staff Year,
Fiscal Years 1987 to 1991
Office of the Comptroller General
Washington, DC 20548
December 1992
The President of the Senate
The Speaker of the House of Representatives
In January 1990, in the aftermath of scandals at the Departments of Defense
and Housing and Urban Development, the General Accounting Office began a
special effort to review and report on federal government program areas that
we considered "high risk."
After consulting with congressional leaders, GAO sought, first, to identify
areas that are especially vulnerable to waste, fraud, abuse, and
mismanagement. We then began work to see whether we could find the fundament
al
causes of problems in these high-risk areas and recommend solutions to the
Congress and executive branch administrators.
We identified 17 federal program areas as the focus of our project. These
program areas were selected because they had weaknesses in internal controls
(procedures necessary to guard against fraud and abuse) or in financial
management systems (which are essential to promoting good management,
preventing waste, and ensuring accountability). Correcting these problems is
essential to safeguarding scarce resources and ensuring their efficient and
effective use on behalf of the American taxpayer.
This report is one of the high-risk series reports, which summarize our
findings and recommendations. It describes our concerns over the Internal
Revenue Service's (IRS) ability to collect the tax debts owed the federal
government. It focuses on what IRS needs to do to increase collections. We
believe it is time for IRS to consider fundamental changes that would lead t
o
improved staffing decisions, a shorter collection process, accountability, a
nd
delinquency prevention.
Copies of this report are being sent to the President-elect, the Democratic
and Republican leadership of the Congress, congressional committee and
subcommittee chairs and ranking minority members, the Director-designate of
the Office of Management and Budget, the Secretary-designate of the Treasury
,
and the Commissioner of Internal Revenue.
The Internal Revenue Service (IRS) is responsible both for routine tax
collection and for pursuing delinquent payments. Although IRS routinely
collects about a trillion dollars each year, its efforts to collect delinque
nt
taxes have been inefficient and unbalanced. As a result, billions of dollars
in taxes remain uncollected, representing a serious loss of revenue for the
government.
Moreover, IRS' poor performance in collecting overdue tax debts suggests to
taxpayers that IRS is neither fair nor serious about collecting delinquent
taxes. If IRS were to improve its efforts, the result could be not only
increased revenue but also greater compliance. IRS recognizes its collection
problem and has a number of initiatives under way that address it. But
progress has been slow, and much vigor is needed in the future to enhance
these efforts and bring them to fruition.
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THE PROBLEM
As of the end of September 1991, IRS reported an accounts receivable invento
ry
totaling about $111 billion. IRS estimated that nearly 75 percent of that
amount cannot be collected because either the records are inaccurate and
taxpayers do not actually owe the money, IRS cannot locate the taxpayers, or
the taxpayers cannot pay. That leaves almost $30 billion that IRS has
estimated as potentially collectible.
IRS based these estimates on its record of success at collecting delinquent
taxes. If IRS were to improve its ability to collect, it could recoup more o
f
the unpaid debt. Yet IRS' collections have actually declined, dropping by 5
ercent in fiscal year 1991. Meanwhile, reported delinquent tax debts--the
accounts receivable inventory--continue to grow and age.
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THE CAUSES
Several problems have interfered with IRS' ability to collect unpaid taxes.
First, the agency's records are inaccurate and insufficient. Because IRS doe
snot know how many accounts are valid, its estimates of receivables are
unreliable as a measure of performance. Because IRS employees do not know
which accounts are valid, they waste time and money pursuing nonexistent
debts. And because IRS cannot tell which of its many collection tools produc
es
the best results, the agency has not known how best to direct its efforts.
Second, the collection process is lengthy, antiquated, rigid, and inefficien
t.
The first step of the process alone may take 6 months. By comparison,
delinquencies in the private sector are usually resolved in 6 months.
Third, IRS has had difficulty balancing collection efforts with the need to
protect the taxpayer--an objective embodied in legal restrictions on IRS'
efforts.
Fourth, IRS' decentralized structure tends to blur lines of responsibility a
nd
accountability.
And fifth, IRS does not have enough information to allocate staff effectivel
y.
Staffing varies dramatically among districts and is independent of collectio
n
needs.
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GAO'S SUGGESTIONS FOR IMPROVEMENT
We have made numerous recommendations to IRS over the years to improve its
collection efforts; IRS has responded to some. For example, IRS has begun to
develop much-needed information on the age of delinquencies and the types of
taxpayers and taxes making up the accounts receivable inventory.
But many areas remain to be addressed. Among other actions, IRS should gathe
r
more and better data and use that data as a basis for decisions. IRS could
also shorten and improve its debt collection process and remove organization
al
impediments to collections and determine the appropriate size and mix of
collection staff. Further, Congress could revisit the issue of the appropria
te
balance between the need to protect taxpayers and the need to collect
delinquent tax debts.
The government has the opportunity to realize substantially more revenue fro
m
taxes already owed if it could more effectively and efficiently carry out th
e
process of collecting those debts. Still, even as IRS works to improve
collection methods, it should also give attention to preventing taxpayers fr
om
becoming delinquent in the first place. In addition to pursuing its current
strategy for increasing compliance, IRS would do well to examine existing ta
x
rules, whose complexity may encourage delinquencies. A good example is IRS'
recent simplification of employment tax deposit rules--another of our
recommendations. And, in general, ensuring that IRS' operations are competen
t
and evenhanded may also help maintain public trust and voluntary compliance
with our tax laws.
IRS is responsible for collecting $1 trillion in taxes each year and for
ensuring that people pay their fair share of taxes. Some Americans do not
report all of their income or claim too many deductions. The taxes that they
should have paid make up the so-called "tax gap." As part of its job, IRS
attempts to identify delinquent taxes--whether they stem from honest mistake
s,
inability to pay, or outright fraud. Once debts are identified, IRS classifi
es
them as accounts receivable.
Few people would question the wisdom of pursuing known delinquencies. Yet IR
S'
poor performance in collecting unpaid taxes has suggested that the agency ha
s
not been seriously committed to this task. For many years, IRS has collected
only a small portion of the billions of dollars of reported accounts
receivable, and its own numbers showed that its collections have actually
declined even as the accounts receivable inventory has grown. Moreover, IRS'
collection efforts have been unbalanced; they have not always been
proportionate to the severity or the geographic distribution of the
delinquencies themselves.
Inefficient and inequitable collection efforts not only mean lost or delayed
revenue, but they have broader consequences as well: the public comes to
believe that IRS is not fair in its operations and is not serious about
collecting unpaid taxes. Allowing some people to get away without paying the
ir
tax debts may discourage voluntary compliance among the millions of taxpayer
s
who do pay their share. At the same time, IRS does little to prevent taxpaye
rs
from becoming delinquent in the first place. An approach emphasizing
delinquency prevention could help reduce the need for collections.
BILLIONS OF DOLLARS UNCOLLECTED
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As of the end of September 1991, IRS reported that its accounts receivable
inventory totaled about $111 billion. On the basis of experience, IRS
estimated that nearly 75 percent of the inventory will never be collected
because either records are inaccurate and the taxpayers do not actually owe
the money, IRS cannot locate the taxpayers, or the taxpayers cannot pay. Thi
s
leaves almost $30 billion that IRS has estimated as potentially collectible,
assuming that IRS maintains its current rate of collections. Clearly, improv
ed
collection efforts would mean more of this debt would be recovered.
As figure 1 shows, even as the reported accounts receivable inventory has
continued to grow and age, collections have not kept pace. For fiscal year
1991, IRS reported that collections of receivables actually declined by 5
percent while its receivables inventory increased by 15 percent.
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Figure 1: IRS' Delinquent Tax Collections and Accounts Receivable Trends,
Fiscal Years 1988 to 1991
The following table represents the data for this chart in the printed versio
n
of the report. The actual figure appears in the printed report.
(Dollars in Billions)
Change in
Total Change in Change in
Delinquent Accounts Total
Tax Over Accounts
Fiscal Year Collections 1 Year Old Receivable
=========== =========== ========== ===========
1988 0.000 0.000 0.000
1989 0.183 7.811 11.522
1990 2.156 16.552 20.794
1991 0.973 27.214 29.122
Note 1: All values include interest and penalties on Individual and Business
Master File accounts.
Note 2: Fiscal year 1991 inventory and age data have been adjusted from a
10-year to a 6-year statutory collection period.
Several conditions have interfered with IRS' ability to collect unpaid taxes
These include a lack of complete and accurate information about accounts, an
inefficient collection process, the need to balance collection efforts with
taxpayer protection, a highly decentralized organizational structure, and
uneven staffing among offices.
LACK OF INFORMATION
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IRS' collection efforts have long been hampered by erroneous and insufficien
t
information. To begin with, IRS' accounts are riddled with errors and
duplications; many of the recorded debts do not even exist. Moreover, IRS do
es
not collect some information that could help it better guide its efforts.
These problems mean that IRS does not know how many accounts are valid, whic
h
accounts are worth pursuing, and which of its collection tools are most
effective in particular cases. As a result, IRS wastes valuable resources
because it cannot productively focus its collection efforts.
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HOW MANY ACCOUNTS ARE VALID
In general, IRS has reported accounts receivable significantly higher than
could ever be collected; IRS itself estimated that less than $30 billion of
ts $111 billion inventory is collectible. Yet because IRS does not know how
many records are valid, no one really knows the true number of receivables,
much less how many of them are collectible. We are now reviewing IRS account
s
receivable as part of our onging financial audit required by the Chief
Financial Officers (CFO) Act of 1990. Our preliminary data suggest that even
IRS' estimate of $30 billion in potential collections may be overstated.
Because Members of Congress and the public have relied on IRS' information,
many have an exaggerated idea of the impact increased collections could have
on reducing the deficit. Members have also depended on these inflated figure
s
when making decisions about IRS' staffing needs.
The financial audit should provide, for the first time, a reliable estimate
of
IRS' collectible receivables, based on a detailed analysis of a statistical
sample of individual accounts. IRS' annual audited financial statements will
also give Congress credible information on receivables and IRS' other
operations for oversight and accountability.
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WHICH ACCOUNTS ARE VALID
While the overall number of valid accounts can be estimated from an analysis
such as ours, no one knows specifically which accounts are valid and which
ones are not. This uncertainty has several implications.
First, because IRS employees trying to collect individual tax debts do not
know which accounts are valid, they waste time and money pursuing debts that
are not real and will not generate revenue. In addition, taxpayers who are
contacted about nonexistent debts feel harassed and may lose confidence in
IRS' competence and fairness.
Second, no one knows how invalid accounts are distributed among IRS' various
offices. Nor does anyone know how much time it takes to resolve an invalid
account. Because of these uncertainties, there is no way to determine whethe
rsome offices are managing proportionately more workload with less payoff.
Third, what summary information IRS does have reflects both valid and invali
d
accounts. This makes it unreliable as a basis for decisions on staffing or
collection strategies.
In the last few years, IRS has taken steps to develop such basic information
as the age of the accounts receivable, types of tax owed, and how closed
accounts were resolved. IRS is now working on the largest accounts to identi
fy
and remove errors, prevent future errors, and identify obstacles to increasi
ng
collections. IRS also plans to study why some tax debts have been abated. Th
is
is a start, but it will not be enough. IRS needs accurate and complete
information on all of its accounts.
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WHICH TOOLS WORK BEST
To develop a good collection strategy, IRS needs far more information than i
t
currently has about the nature of tax debts, the characteristics of delinque
nt
taxpayers, and the relative effectiveness of collection tools. Without these
data, IRS does not know which of its approaches work best, in which cases th
ey
work best, or when in the collection process they work best.
Congress has provided IRS with an extensive array of collection tools: IRS m
ay
negotiate installment agreements, settle for lesser amounts, garnish wages,
levy bank accounts, and seize assets. IRS uses these tools frequently and
often automatically, but it has no solid data with which to guide their use.
For example, IRS knows that its employees garnish wages or levy bank account
s
more than 2 million times each year. But IRS does not know how much money is
collected in this way, how often the debt is satisfied as a result, or how
often the bank account is empty by the time the levy notice arrives. Nor doe
s
IRS know whether one of these techniques is more productive than the other o
r
whether it is more effective to use one before the other.
Similarly, IRS does not know the most effective collection approaches for
specific types of tax debts or taxpayers. For example, employment taxes
(employee wages withheld for social security and income taxes as well as the
employer's share of social security taxes) make up about a third of reported
accounts receivable--a sizable amount. IRS has specific tools to apply to
employment tax debts. But IRS does not know whether these tools are in fact
used for such accounts, much less whether they are successful.
Since the late 1970s, we have been pointing out that IRS needs better
information to manage and evaluate its collection activities. Without it, IR
S
has no empirical basis for selecting a cost-effective mix of collection tool
s
and programs. With it, IRS could allocate staff and other resources in a way
that would recover more revenue.
IRS' annual audited financial statements should help in part by enabling the
agency to better measure its collection performance and, in turn, better
direct its collection efforts. The ability to tie program decisions to
financial results in this way is one goal of the CFO Act.
INEFFICIENT COLLECTION PROCESS
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Good business practice dictates that after a debt arises, efforts be made to
secure some type of payment agreement as quickly as possible. IRS' decades-o
ld
collection process, however, is not based on this premise. The IRS collectio
n
process involves three steps. In step one, IRS mails the taxpayer a series o
f
three to five computer-generated bills, at 30-day intervals, to notify the
taxpayer that a tax debt is owed. In step two, IRS telephones the taxpayer t
o
collect the money or otherwise resolve the debt. In step three, a revenue
officer visits the taxpayer. In most IRS offices, smaller debts are not
handled until a revenue officer becomes available or until the debt (which i
s
accumulating interest) grows large enough to be of higher priority. If not
handled, the revenue will be lost when the 10-year statute of limitations
expires.
The process is outdated, costly, and inefficient. A comparison with private
sector debt collection illustrates several areas in which the IRS process
needs improvement.
First, IRS' process takes too long. Delinquencies in the private sector are
usually closed after 180 days. By that time, IRS has probably not even tried
to telephone the taxpayer. IRS officials have explained that one reason the
agency spends up to 6 months sending bills is to clear up as many errors as
possible before employing more intrusive and more costly collection
techniques. Correcting errors is important, especially since so many occur,
but this could be done more quickly by telephone. Another reason IRS takes s
o
long is to allow enough time to receive and verify any replies from the
taxpayer and to update the taxpayer's account. This is a time-consuming
process in IRS' antiquated computer environment.
IRS is now in the midst of a long-term massive computer modernization effort
that should eventually create an environment in which taxpayer information i
s
not only timely and accurate from the beginning but is also available to any
IRS employee that needs it to do the job. Recent IRS commissioners have
recognized the importance of this modernization initiative and have built on
their predecessors' efforts to bring it to reality. This trend must continue
Second, the process is too rigid. IRS follows the same three-step process fo
r
all types of accounts. If a debt remains unpaid, IRS will eventually use its
more powerful tools, regardless of the taxpayer's compliance history. In
contrast, private debt collectors often tailor their collection process to t
he
individual delinquent on the basis of experience or analyses of the behavior
of specific types of delinquents. IRS is beginning to make some changes. For
example, the agency now allows employees who have early contact with
delinquent taxpayers to attempt collection before the first bill is sent. Bu
t
such movement toward change has been slow.
Third, the IRS collection process relies too heavily on step three, visits b
y
a revenue officer. Private sector companies avoid personal contact because o
f
the cost and potential dangers involved. Although IRS may need some personal
contact--to exercise its seizure power, for example--it may not need to give
this method the emphasis it currently has.
BALANCING COLLECTION EFFORTS WITH TAXPAYER PROTECTION
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IRS' attempts to collect debts using the same tools regardless of the
taxpayer's compliance history--and, in some cases, even when the debt was no
t
actually owed--led, understandably, to complaints from taxpayers. To ensure
that IRS always treats taxpayers fairly and does not abuse the substantial
powers it has to enforce the tax laws, Congress passed the Taxpayer Bill of
Rights in 1988 to strengthen taxpayer protections and placed conditions on
IRS' use of certain collection tools. An unintended result of this legislati
on
was to hamper tax collection, both because of elements of the legislation
itself and because IRS has evidently become reluctant to take actions that
might provoke further constraints.
For example, one provision of the 1988 legislation prohibits IRS from
evaluating staff members on the basis of dollars collected. IRS already had
a
similar policy, but Congress was concerned that the policy was not followed
and that IRS employees, perceiving a "quota" system, were too harsh in their
collection efforts. We said then, and continue to believe now, that taxes
collected is a reasonable basis on which to judge the performance of employe
es
whose job it is to collect taxes, as long as other criteria, such as fair an
d
courteous treatment of taxpayers, are also evaluated. Virtually all private
sector collection managers with whom we talked said that dollars collected w
as
one criterion used to evaluate employees and that it would be difficult to
have an effective collection operation if dollars collected could not be use
d
to evaluate performance.
Under IRS' current system of evaluating staff performance, accounts classifi
ed
"currently not collectible" are given the same weight as dollars collected.
This could contribute to the fact that the single largest segment of the
accounts receivable inventory--and one of its fastest growing portions--is
accounts deemed "currently not collectible." As shown in figure 2, district
office staff now declare more tax debt "currently not collectible" than they
collect.
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Figure 2: District Office Staff Collections Compared to Dollars Added to
Currently Not Collectible Status, Fiscal Years 1987 to 1991
The following table represents the data for this chart in the printed versio
n
of the report. The actual figure appears in the printed report.
(Dollars in Billions)
Dollars
Collected
by Dollars
District Added to
Office Currently Not
Fiscal Year Staff Collectible
=========== ========= =============
1987 6.4 3.2
1988 6.4 4.3
1989 6.7 6.0
1990 7.0 7.8
1991 7.2 8.4
Further, perhaps to avoid prompting further legislative intervention, IRS
collection agents now seem reluctant to use some of the tools available to
them. For example, the number of cases in which IRS seized property dropped
from 25,000 in 1985 to less than 10,000 in 1991. Also, IRS staff has stopped
collection action, even when taxpayers earn a substantial income, if the
taxpayers have reported an equal amount of expenses to maintain their existi
ng
lifestyle.
These results reflect IRS' struggle to balance the need to protect the right
s
of taxpayers with the need to collect tax debts. IRS must be fair; its
employees should follow appropriate laws and procedures and not harass
taxpayers. But on the other hand, taxpayers need to know that IRS is serious
about collecting taxes.
IRS' organizational structure has impeded its ability to implement nationwid
e
changes. IRS is a highly decentralized organization: all 7 regions, 63
districts, and 10 service centers share responsibility for collecting tax
debts. Each district has a great deal of independence in deciding which
accounts to pursue and which tools to use in pursuing them. Assistant
commissioners in IRS' National Office direct various functions--including
collection, examination, returns processing, taxpayer service, and criminal
investigation--but none of these people has direct line authority over field
operations.
In 1991, IRS took a step toward establishing a unified collection strategy b
y
appointing an accounts receivable executive officer who reports to IRS' chie
f
financial officer. IRS also appointed multifunctional task forces to study
specific aspects of the collection problem. The accounts receivable executiv
e
officer and the task forces face the challenge of operating in a decentraliz
ed
organization in which they have no line authority over the people directly
responsible for collections.
IRS is also using a strategic planning process to improve accountability.
Executives are expected to meet goals and annual targets. The 1992 collectio
n
target, for example, calls for the accounts receivable inventory to remain
level or decrease and for debt collections to increase by 8 percent. The
strategic planning process seems to have prompted better interunit
cooperation, but so far tax debt collection has not improved.
IRS' traditional solution to collection problems has been to add staff. Give
nincreasing tax debts and number of accounts waiting to be handled, it would
be
easy to conclude that more staff is the best response. However, although we
supported the staff increase Congress authorized IRS for 1991, we noted that
more staff is not necessarily the answer in the long term. We also cautioned
policymakers not to overestimate the amount of additional revenue that would
result from adding staff. Debt collections actually declined that year.
IRS' own experience suggests that there is reason to doubt that adding staff
will automatically lead to better collections. To begin with, productivity o
f
collection staff has not been constant. As figure 3 shows, the number of
accounts closed per staff year in district offices has fluctuated considerab
ly
since 1987.
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Figure 3: Percent Change in Revenue Officer Case Closures per Staff Year,
Fiscal Years 1987 to 1991
The following table represents the data for this chart in the printed versio
n
of the report. The actual figure appears in the printed report.
Source: GAO analysis of IRS data.
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___
Further, IRS may not be making the best use of the staff it already employs.
Imbalances are common. In some districts, enough staff is available to pursu
e
small debts as well as large ones while in other districts large debts go
uncollected because staff is not available. Aside from the potential revenue
losses, such imbalances mean that taxpayers in different parts of the countr
y
are treated differently.
Therefore, rather than simply adding staff, IRS must ensure that it is makin
g
effective use of its staff. Because of IRS' lack of data, little is known
about the optimum size and mix of staff for collections. Without better
information, IRS cannot make rational decisions on how best to allocate staf
f
in the long term.
CONCLUSIONS AND ACTION NEEDED
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We have made numerous recommendations over the years to IRS on ways to impro
ve
its tax debt collection efforts. In the last several years, IRS has begun
responding to some of these recommendations. For example, IRS is developing
much-needed information on the age of delinquencies and the types of taxpaye
rs
and taxes making up the accounts receivable inventory. And IRS has improved
its review process for evaluating the performance of field offices and start
ed
to identify performance measures that reflect its mission. IRS has also
responded to our most significant recommendation on preventing employment ta
x
delinquencies by simplifying the requirements for employment tax deposits,
making it easier for employers to understand and comply with the rules. In
addition, as required by the CFO Act of 1990, IRS is now preparing an annual
financial statement that we are auditing.
But many areas still need improvement, and the next commissioner must build
upon the successes of prior commissioners. Most of our recommendations have
addressed IRS' need to gather more and better data and to use that data as a
basis for decisions. Among other steps, we have recommended that the agency
develop more specific information on the validity and characteristics of
accounts that are written off to determine whether new collection measures
might help. We have recommended that IRS gather more extensive information o
n
employment tax delinquencies and measure the effectiveness of IRS programs f
or
dealing with them. And we have recommended that IRS find ways to give Congre
ss
more reliable estimates of revenues expected from proposed staffing increase
s.
We have also proposed ways in which IRS could improve the collection
process--for example, by analyzing the experience of private industry and by
setting priorities on the basis of likelihood of collection rather than on t
he
size of the debt. In addition, IRS should identify and correct elements of i
ts
organizational structure that impair its collection ability and should work
with the Office of Management and Budget to determine the appropriate size a
nd
mix of collection staff. And we have suggested that Congress revisit the iss
ue
of balancing the need to protect taxpayers and the need to collect delinquen
t
tax debts.
Perhaps most important, IRS must remember that collections are only part of
its job. Even as it works to improve collection methods, IRS should also giv
e
attention to preventing taxpayers from becoming delinquent in the first plac
e.
Preventing delinquencies would reduce the problem--and cost--of collecting t
ax
debts later on. In addition, tax revenues would be more certain, and the mon
ey
would be available for use sooner. IRS' delinquency prevention programs are
modest; the agency has agreed that it could do more in this area and recentl
y
introduced a strategy called Compliance 2000.
By ensuring that its operations are evenhanded and competent, IRS could do
much to prevent the loss of public trust that can contribute to delinquency.
In addition, although IRS has taken a step forward by simplifying employment
tax deposit requirements, IRS needs to take a close look at the complexity o
f
other tax rules, which are often thought to cause taxpayers to become
delinquent. Taxpayers plan their finances on the basis of their understandin
g
of the rules. By the time they learn their understanding was wrong, they may
not have the money to pay additional taxes. IRS needs to identify the specif
ic
rules that cause the most problems and work with the Department of the
Treasury and the Congress to simplify them.
The federal government has the opportunity to realize substantial revenue fr
om
taxes already owed if it can more effectively and efficiently carry out the
process of collecting those debts. The delinquency problem is not
straightforward, and it will not be easy to fix. But given the loss of
billions of dollars in revenue--and the corresponding loss of public
confidence in the system--IRS must aggressively address this problem as
quickly as possible.
