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entitled 'Tax Gap: IRS Could Do More to Promote Compliance by Third 
Parties with Miscellaneous Income Reporting Requirements' which was 
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Report to the Committee on Finance, U.S. Senate: 

United States Government Accountability Office: 
GAO: 

January 2009: 

Tax Gap: 

IRS Could Do More to Promote Compliance by Third Parties with 
Miscellaneous Income Reporting Requirements: 

GAO-09-238: 

GAO Highlights: 

Highlights of GAO-09-238, a report to the Committee on Finance, U.S. 
Senate. 

Why GAO Did This Study: 

Third party payers, often businesses, reported $6 trillion in 
miscellaneous income payments to IRS in tax year 2006 on Form 1099-MISC 
information returns. Payees are to report this income on their tax 
returns. Even a small share of payers failing to submit 1099-MISCs 
could result in billions of dollars of unreported payments. IRS data 
suggest that payees are more likely to report income on their tax 
returns if IRS receives payers’ information returns. 

GAO was asked to examine 1099-MISC reporting including the extent to 
which payers fail to submit 1099-MISCs; impediments to payers to 
submitting1099-MISCs; and whether IRS could better use the 1099-MISCs 
it currently receives. GAO reviewed IRS documents and compliance data 
and interviewed officials from IRS, its advisory groups, and others who 
advise 1099-MISC payers. 

What GAO Found: 

he Internal Revenue Service (IRS) does not know to what extent payers 
fail to submit required 1099-MISCs, but various sources point to the 
possibility of a significant problem. For tax year 2005, 8 percent of 
the approximately 50 million small businesses with assets under $10 
million submitted 1099-MISCs, but IRS does not know how many of the 
other 92 percent were required to report payments but did not. Many 
business payments, such as payments to corporations, are not subject to 
1099-MISC reporting. If even a small share of the businesses that did 
not submit a 1099-MISC should have, millions of 1099-MISCs could be 
missing with significant amounts of unpaid taxes by payees. GAO’s prior 
work in 2003 found significant 1099-MISC payer noncompliance by some 
federal agencies.IRS could mitigate costs for research on payer 
noncompliance by building on its existing research programs. 

Figure: Numbers of Small Businesses Filing Tax Returns and 1099-MISCs, 
Tax Years 2002 to 2005 (in thousands): 

[Refer to PDF for image: vertical bar graph] 

Tax year: 2002: 
Small businesses filing tax returns: 44,571; 
Small businesses submitting 1099-MISCs: 3,873. 

Tax year: 2003: 
Small businesses filing tax returns: 46,095; 
Small businesses submitting 1099-MISCs: 3,966. 

Tax year: 2004: 
Small businesses filing tax returns: 48,501; 
Small businesses submitting 1099-MISCs: 4,088. 

Tax year: 2005: 
Small businesses filing tax returns: 50,075; 
Small businesses submitting 1099-MISCs: 4,198. 

Source: GAO analysis of IRS data. 

[End of figure] 

Payers face a variety of impediments that may contribute to 1099-MISC 
noncompliance, including complex reporting requirements and an 
inconvenient submission process. For example, certain payments to 
unincorporated persons or businesses are subject to 1099-MISC 
reporting, but payments to corporations generally are not, requiring 
payers to determine the status of their payees. GAO in the past 
determined that the benefits in terms of increased tax revenue and 
improved taxpayer compliance justify eliminating this distinction. 

IRS agrees, and the Bush Administration’s proposal to do so would have 
required legislative action. Other options to remind payers about their 
reporting obligations include adding a tax return checkbox asking if 
payers submitted required 1099-MISCs and adding a chart to help payers 
navigate the detailed instructions for the Form 1099-MISC. 

IRS matches what the payees report on their tax returns to what payers 
report on 1099-MISCs to detect payees underreporting income and taxes. 

But IRS does not pursue all mismatches its computers detect. If IRS 
were to increase payer compliance with 1099-MISC requirements, the 
number of mismatches would likely increase. However, IRS does not 
systematically collect information on the causes of mismatches or 
whether they could be prevented. 

What GAO Recommends: 

Congress should consider requiring payers to report payments to 
corporations on the Form 1099-MISC. GAO also makes eight 
recommendations to IRS, including researching the extent of and reasons 
for payer noncompliance; identifying common reporting errors; and 
providing more guidance about 1099-MISC requirements. IRS agreed with 
six of GAO’s recommendations but disagreed with evaluating the checkbox 
option and adding a chart to the 1099-MISC instructions. GAO maintains 
its support for all recommendations. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.gao.gov/products/GAO-09-238]. For more 
information, contact James R. White at (202) 512-9110 or 
whitej@gao.gov. 

[End of figure] 

Contents: 

Letter: 

Results in Brief: 

Background: 

IRS Has Little Information about 1099-MISC Reporting Compliance, but 
Available Evidence Points to the Possibility of a Significant Problem: 

IRS Efforts to Detect Payers That Fail to Submit 1099-MISC Forms Are 
Uneven: 

Payers Face Impediments in Preparing and Submitting 1099-MISCs, and 
Some Options Could Help Promote Voluntary Reporting Compliance by 
Payers: 

IRS Aims to Improve AUR Efficiency but Lacks a Systematic Process for 
Learning about the Causes of Mismatches: 

Conclusions: 

Matter for Congressional Consideration: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: Comments from the Internal Revenue Service: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: Impediments to 1099-MISC Payer Reporting Compliance and 
Options for Increasing Voluntary 1099-MISC Compliance: 

Table 2: 1099-MISC-Related Cases Represent a Significant Share of the 
Cases Selected for AUR Review and Taxes Assessed, Tax Year 2004: 

Figures: 

Figure 1: Form 1099-MISC, 2007: 

Figure 2: Numbers of 1099-MISC Payments by Type and Total Amounts 
Reported by Payers to IRS, Tax Year 2006: 

Figure 3: Paper and Electronic Submissions by Payer Categories, Tax 
Year 2006: 

Figure 4: Matching 1099-MISC Reportable Nonemployee Compensation 
Information with Individual Tax Returns: 

Figure 5: Aggregate Comparison of the Number of Small Businesses Filing 
Tax Returns and Number of Small Businesses Submitting 1099-MISCs, Tax 
Years 2002 to 2005: 

Figure 6: California State Tax Forms for Corporations and S 
Corporations, Tax Year 2007: 

Abbreviations: 

AUR: Automated Underreporter Program: 

EIN: employer identification number: 

ETAAC: Electronic Tax Administration Advisory Committee: 

FIRE: Filing Information Returns Electronically: 

IRPAC: Information Reporting Program Advisory Committee: 

IRS: Internal Revenue Service: 

IRSAC: Internal Revenue Service Advisory Council: 

LMSB: Large and Mid-Size Business Division: 

NRP: National Research Program: 

PMF: Payer Master File: 

SB/SE: Small Business and Self-Employed Division: 

SOI: Statistics of Income: 

SCRIPS: Service Center Recognition Image Processing System: 

SSN: Social Security Number: 

TE/GE: Tax Exempt and Government Entities Division: 

TIGTA: Treasury Inspector General for Tax Administration: 

TIN: taxpayer identification number: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

January 28, 2009: 

The Honorable Max Baucus: 
Chairman: 
The Honorable Charles Grassley: 
Ranking Member: 
Committee on Finance: 
United States Senate: 

For tax year 2006, third parties submitted more than 82 million 
miscellaneous income information forms (Form 1099-MISC) to the Internal 
Revenue Service (IRS) reporting more than $6 trillion in payments. 
Third party payers are businesses, governmental units, and other 
organizations that make payments to other businesses or individuals. 
Payers must submit payment information on 1099-MISCs to IRS when they 
make a variety of payments labeled miscellaneous income.[Footnote 1] 
Payees, or those being compensated, are required to report the payments 
on their income tax returns. By matching 1099-MISCs received from 
payers with what payees report on their tax returns, IRS can detect 
underreporting of income including failure to file a tax return. 

Payer noncompliance with 1099-MISC reporting requirements undercuts 
IRS's ability to detect underreporting of income by payees and, as a 
consequence, contributes to the tax gap. This contribution may be 
large.[Footnote 2] IRS has long recognized that if payments made to 
businesses are not reported on 1099-MISCs, it is less likely that they 
will be reported on payee tax returns. Based on IRS's most recent tax 
gap estimates, we reported that for tax year 2001 sole proprietors 
(individual owners of unincorporated businesses) understated their 
taxes by an estimated $68 billion because of underreporting their net 
income.[Footnote 3] An unknown proportion of this income could have 
been reported to IRS on 1099-MISCs but was not. 

Other limited evidence also shows payer noncompliance with 1099-MISC 
reporting requirements. In 2003, we reported that some federal agencies 
failed to submit required 1099-MISCs covering billions of dollars of 
payments.[Footnote 4] A 2007 report by the Treasury Inspector General 
for Tax Administration (TIGTA) suggests that some state and local 
governments may also not be submitting required 1099-MISCs.[Footnote 5] 

Because of your concern about the tax gap, you asked us to study 1099- 
MISC reporting and whether IRS can make more use of 1099-MISC 
information that it already receives. Specifically, our objectives were 
to determine (1) what IRS knows about 1099-MISC reporting noncompliance 
by payers; (2) how IRS detects and pursues 1099-MISC reporting 
noncompliance by payers; (3) what impediments payers encounter in 
preparing and submitting accurate 1099-MISC forms, and what options 
could help IRS address these issues; and (4) what opportunities exist 
to enhance IRS's use of 1099-MISC information to detect payee 
noncompliance and promote voluntary taxpayer compliance. 

To address these objectives, we reviewed IRS data, IRS documents, 
including advisory group reports; past GAO and TIGTA reports on 1099- 
MISC reporting compliance; IRS's procedures for checking compliance; 
and plans and proposals to expand 1099-MISC reporting. We also 
interviewed IRS officials and members of IRS advisory groups, tax 
professionals, and tax software and information return filing vendors 
to identify impediments facing payers in preparing and submitting 1099- 
MISCs. We interviewed IRS officials on the operations of the Automated 
Underreporter Program (AUR) which matches the payee's tax return 
against 1099-MISCs submitted by payers so that IRS can detect taxpayer 
underreporting; we reviewed AUR program data for tax year 2004 (the 
last full year available). We also analyzed data from the IRS's Payer 
Master File (PMF) and information reporting program data about 1099- 
MISCs submitted for tax year 2006. To obtain perspective on the 
potential magnitude of payer noncompliance, we compared the aggregate 
numbers of small businesses filing tax returns with the numbers 
submitting 1099-MISCs for tax years 2002 to 2005.[Footnote 6] Using 
IRS's Statistics of Income data for tax year 2006, we estimated the 
1099-MISC submission rate for a sample of Schedule C small businesses. 
We assessed the IRS data and found they were sufficiently reliable for 
the purposes of this report. We conducted this performance audit from 
June 2007 through January 2009 in accordance with generally accepted 
government auditing standards. Those standards require that we plan and 
perform the audit to obtain sufficient, appropriate evidence to provide 
a reasonable basis for our findings and conclusions based on our audit 
objectives. We believe that the evidence obtained provides a reasonable 
basis for our findings and conclusions based on our audit objectives. 
(See appendix I for more information on our scope and methodology.) 

Results in Brief: 

IRS does not know the magnitude of 1099-MISC payer noncompliance or the 
characteristics of payers that fail to comply with the reporting 
requirements. Without an estimate of payer noncompliance, IRS has no 
way of determining to what extent 1099-MISC payer noncompliance creates 
a window of opportunity for payees to underreport their business income 
and go undetected by IRS. Available evidence points to the possibility 
of a significant problem with 1099-MISC payer noncompliance. Among 
small businesses (sole proprietors, and partnerships and corporations 
with assets under $10 million), 8 percent of those filing tax returns 
also submitted 1099-MISCs for tax year 2005. For Schedule C small 
businesses that reported $600 or more in contract labor expenses in 
2006, we estimated that about 29 percent submitted 1099-MISCs, but we 
could not determine whether the other 71 percent were noncompliant 
given current reporting exemptions. The relatively small percentages 
submitting 1099-MISCs do not indicate that payers are not complying 
with 1099-MISCs reporting requirements, given the many exceptions that 
exempt payers from having to submit 1099-MISCs. However, IRS does not 
know how much of it may be because of payer noncompliance. Research 
about the extent of payer noncompliance could help IRS target outreach 
to payer groups and develop strategies to increase 1099-MISC reporting 
compliance. To mitigate costs, IRS could build on its existing research 
tools to study whether small businesses submitted their 1099-MISCs as 
required or identify reporting patterns using its payer history data. 

IRS does not have an agencywide approach for detecting 1099-MISC payer 
noncompliance. For federal, state, and local government payers, 
examiners scrutinize information reporting compliance and identified 
over 30,000 missing 1099-MISCs totaling over $522 million in payments 
for tax years 2005 through 2007. In response to our recommendation in 
2003, IRS developed an automated "stop filer" program to notify federal 
agencies that submitted 1099-MISC one year but not the next. At this 
time, IRS does not generate notices for state and local entities that 
stop submitting 1099-MISCs and is working to update its payer history 
files for state and local governments. For business payers, examiners 
focus on income and employment tax liabilities that are likely to 
produce larger tax assessments than the penalties they would apply for 
missing 1099-MISCs. Further, examinations are costly and cover 
relatively few businesses each year, and thus would not be cost- 
effective as the sole means to address 1099-MISC reporting compliance. 
Yet, IRS does not have a systematic program in place to identify payers 
with gaps in their 1099-MISC reporting history or those that never 
submit the 1099-MISC forms. For example, IRS does not have any program 
for businesses similar to its federal stop filer program. Options for 
testing how to design a cost-effective stop filer notice program for 
businesses could include first checking to see whether a business filed 
a tax return before inquiring about 1099-MISCs or targeting notices to 
businesses reporting large contract labor expenses. 

According to IRS, advisory group members, and others we interviewed, 
payers are confronted with a variety of impediments to preparing and 
submitting 1099-MISC forms, and some options could help promote 
voluntary reporting compliance by payers. Some payers that do not 
submit their 1099-MISCs as required may be unaware of their 1099-MISC 
reporting responsibilities. Other payers may be confused about whether 
payments are reportable because of different dollar reporting 
thresholds and the general exemption for payments to corporations. For 
the large number of payers each submitting a few 1099-MISCs, IRS does 
not offer a fillable form on its Web site and requires payers to submit 
scannable red ink forms, but some payers submit black and white 1099- 
MISCs anyway. Addressing payers' concerns and making it easier to 
comply with 1099-MISC requirements could promote voluntary information 
reporting compliance. IRS could consider options, including those 
requiring legislative action, that it determines as cost efficient and 
would not impose undue burdens on payers or the agency itself. One 
option is removing the general exemption on reporting payments made to 
corporations, which would lessen the burden for payers of having to 
determine the payee business type and also provide information to help 
IRS detect underreported miscellaneous income. Since 1991, we have 
reported that the benefits would exceed the cost for this approach. 
According to the Department of the Treasury's estimate, the Bush 
Administration's fiscal year 2009 proposal for reporting payments to 
corporations would generate about $8.2 billion from 2009 through 2018, 
in part because of increased voluntary compliance. Other options 
involve adding a checkbox on tax returns attesting to the submission of 
1099-MISCs as required and adding a chart to business tax instructions 
to help payers distinguish reportable from non-reportable payments, 
both of which could serve as reminders of 1099-MISC reporting 
responsibilities. 

For tax year 2004 (the last full year available), the AUR program 
assessed $972 million in additional taxes for payee underreporting 
detected using 1099-MISC information. The AUR program currently has a 
narrow reach and pursues less than half of 1099-MISC-related cases in 
the AUR inventory. To improve efficiency of the AUR program, IRS is 
rolling out a new "soft notice" contacting additional taxpayers in the 
AUR inventory and asking them to amend their returns to fix the 
underreporting. Soft notices may be a cost-effective way for IRS to 
expand its enforcement presence using 1099-MISC information, but it is 
too early to assess this new approach. Another way to free up AUR 
resources to work more cases is to reduce the number of unproductive 
cases that do not yield any additional tax revenue. In 2004, more than 
one-third of 1099-MISC cases selected for AUR review were manually 
screened out before taxpayer contact, and nearly one-quarter of those 
with taxpayer contact resulted in no tax change. Currently, IRS does 
not systematically collect information on the causes of unproductive 
AUR cases and had not conducted analyses to identify common 1099-MISC 
reporting errors. Such information could help IRS both to refine its 
AUR case selection and to target outreach helping payers and payees 
report 1099-MISC payments correctly. 

We are suggesting that Congress consider amending the Internal Revenue 
Code to require third-party payers submit 1099-MISCs for service 
payments to corporations to reduce payers' burden to determine which 
payments require reporting. We are making several recommendations to 
IRS to help it identify the magnitude and characteristics of payers 
that do not comply with 1099-MISC reporting requirements and, using 
such research, to better detect and pursue payers failing to submit 
1099-MISCs. Also, we are recommending ways that IRS can improve payer 
compliance with 1099-MISC reporting requirements, such as providing 
payers with a chart to identify reportable payments and exploring a new 
checkbox on business tax returns for payers to attest whether they 
submitted their 1099-MISC as required. We also recommend that IRS 
collect AUR case data on recurring reporting errors as a way to improve 
guidance and outreach to help payers and payees more accurately report 
1099-MISC payments. 

In written comments on a draft of this report, IRS's Deputy 
Commissioner for Services and Enforcement agreed with six of our eight 
recommendations. However, IRS disagreed with our recommendation to 
assess whether adding a checkbox to business tax returns would increase 
1099-MISC reporting compliance. IRS stated that a similar question was 
removed from the corporate tax return after the Paperwork Reduction Act 
of 1980 was enacted. We believe that the results from the evaluation we 
recommend could be useful to IRS in revisiting its 1981 assessment and 
weighing the benefits and burdens associated with the checkbox option. 
IRS also disagreed with our recommendation to include a chart in the 
1099-MISC instructions and business income tax instructions. IRS stated 
that the Form 1099-MISC instructions already list which payments are 
reportable and explain the rules for specific payment types. We believe 
that a chart would provide taxpayers with a quick guide for navigating 
the eight pages of detailed instructions for the Form 1099-MISC. For 
this reason, we continue to recommend adding a chart to the 1099-MISC 
instructions and business tax instructions. IRS also provided technical 
comments that we incorporated as appropriate. 

Background: 

Payers are required to submit 1099-MISCs for a variety of payments made 
in the course of a trade or business. For 1099-MISC reporting, a trade 
or business generally includes businesses, non-profit organizations, 
and federal, state, and local government agencies. 

The types of payments reportable on a 1099-MISC and their reporting 
thresholds vary widely. These include payments to nonemployees for 
services of at least $600 (called nonemployee compensation), royalty 
payments of $10 or more, and medical and health care payments made to 
physicians or other suppliers (including payments by insurers) of $600 
or more.[Footnote 7] Personal payments, such as a payment by a 
homeowner to a contractor to paint his/her personal residence, are not 
reportable on a 1099-MISC. Other payments that are not reportable on a 
1099-MISC generally include payments to a corporation, payments for 
merchandise, and wages paid to employees. Wages paid to employees must 
be reported on a form W-2. There are many other types of payments that 
must be reported and numerous exceptions to these general rules. IRS 
provides eight pages of instructions detailing what payments to whom 
are reportable on the 1099-MISC.[Footnote 8] The form--shown in figure 
1--consists of 14 boxes for reporting the various types of 
miscellaneous payments.[Footnote 9] 

Figure 1: Form 1099-MISC, 2007: 

[Refer to PDF for image] 

Source: IRS. 

[End of figure] 

The Bush Administration's fiscal years 2008 and 2009 budgets proposed 
legislative action further expanding 1099-MISC reporting to include 
service payments of $600 or more to corporations by all third-party 
payers. According to the Department of the Treasury's estimate, the 
Bush Administration's fiscal year 2009 budget proposal would generate 
about $8.2 billion over the 10-year budget period from 2009 through 
2018, in part because of increased voluntary compliance and IRS's 
ability to detect underreported payments received by businesses. 

For tax year 2006, more than 5 million payers submitted more than 82 
million 1099-MISCs to IRS, reporting over $6 trillion in payments. 
Nonemployee compensation payments totaled about $2.3 trillion and 
accounted for about 55 percent of all 1099-MISCs submitted.[Footnote 
10] Medical and health payments totaled about $1.2 trillion and 
accounted for about 25 percent of all 1099-MISCs submitted. Each of the 
remaining payment types accounted for less than 10 percent of the 
number of 1099-MISCs submitted. Figure 2 shows the distribution of 1099-
MISC payments types and amounts reported for tax year 2006. 

Figure 2: Numbers of 1099-MISC Payments by Type and Total Amounts 
Reported by Payers to IRS, Tax Year 2006: 

[Refer to PDF for image: combined horizontal bar graph] 

Payment type: Non-employee compensation[A]; 
Number of 1099-MISC payments (in thousands): 45,735; 
Total amount reported to IRS (in billions): $2,329. 

Payment type: Medical payments[A]; 
Number of 1099-MISC payments (in thousands): 20,193; 
Total amount reported to IRS (in billions): $1,186. 

Payment type: Rents; 
Number of 1099-MISC payments (in thousands): 5,955; 
Total amount reported to IRS (in billions): $230. 

Payment type: Other income; 
Number of 1099-MISC payments (in thousands): 5,933; 
Total amount reported to IRS (in billions): $254. 

Payment type: Royalties; 
Number of 1099-MISC payments (in thousands): 4,509; 
Total amount reported to IRS (in billions): $42. 

Payment type: Gross attorney fees; 
Number of 1099-MISC payments (in thousands): 1,493; 
Total amount reported to IRS (in billions): $878. 

Payment type: Federal withholding; 
Number of 1099-MISC payments (in thousands): 303; 
Total amount reported to IRS (in billions): $1. 

Payment type: Substitute payment; 
Number of 1099-MISC payments (in thousands): 246; 
Total amount reported to IRS (in billions): $42. 

Payment type: Crop insurance; 
Number of 1099-MISC payments (in thousands): 215; 
Total amount reported to IRS (in billions): $43. 

Payment type: Fishing proceeds; 
Number of 1099-MISC payments (in thousands): 79; 
Total amount reported to IRS (in billions): $8. 

Payment type: Section 409A deferral[B]; 
Number of 1099-MISC payments (in thousands): 67; 
Total amount reported to IRS (in billions): $762. 

Payment type: Section 409A income[B]; 
Number of 1099-MISC payments (in thousands): 15; 
Total amount reported to IRS (in billions): $199. 

Payment type: Excess golden parachute; 
Number of 1099-MISC payments (in thousands): 3. 
Total amount reported to IRS (in billions): $38. 

Source: IRS. 

Note: Data are from IRS's Information Returns Master File. The numbers 
of 1099-MISC payments reported do not total to the number of 1099-MISCs 
submitted by payers because a single 1099-MISC may report more than one 
payment. 

[A] Nonemployee compensation and medical payments include payments to 
corporations. 

[B] Section 409A refers to the section in the Internal Revenue Code 
specifying the tax treatment for nonqualified deferred compensation 
plans. Qualified deferred compensation plans like pensions, retirement 
plans, and stock options are taxed at the time the individual actually 
receives the income. The amount reported as Section 409A income is also 
reported as nonemployee compensation. 

[End of figure] 

In addition to the 8 pages of instructions for 1099-MISC reporting, IRS 
also has 19 pages of general instructions for third-party information 
reporting, detailing how and when payers are to submit 1099-MISCs to 
payees and IRS.[Footnote 11] Payers must provide 1099-MISC statements 
to payees by the end of January. Payers submitting fewer than 250 1099- 
MISCs may submit paper forms, which are due to IRS by the end of 
February, along with a Form 1096, Annual Summary and Transmittal of 
U.S. Information Returns. Payers submitting paper 1099-MISC are 
required to use IRS's official forms or substitute forms with special 
red ink readable by IRS's scanning equipment.[Footnote 12] Photocopies 
and copies of the 1099-MISC form downloaded from the internet or 
generated from software packages in black ink do not conform to IRS 
processing specifications. 

Payers submitting 250 or more 1099-MISCs are required to submit the 
forms magnetically or electronically.[Footnote 13] Electronic 
submissions due at the end of March can be submitted through IRS's 
Filing Information Returns Electronically (FIRE) system. As shown in 
figure 3, most 1099-MISCs for tax year 2006 were submitted 
electronically.[Footnote 14] However, most payers submit small numbers 
of 1099-MISCs, and most payers submitted paper 1099-MISCs. 

Figure 3: Paper and Electronic Submissions by Payer Categories, Tax 
Year 2006: 

[Refer to PDF for image: combined horizontal bar graph] 

1099-MISC forms submitted by each payer: 1 to 4; 
Number of payers, paper (in thousands): 2,893; 
Number of payers, electronic (in thousands): 389; 
Total forms submitted, paper (in thousands): 5,653. 
Total forms submitted, electronic (in thousands): 558. 

1099-MISC forms submitted by each payer: 5 to 9; 
Number of payers, paper (in thousands): 845; 
Number of payers, electronic (in thousands): 82; 
Total forms submitted, paper (in thousands): 5,522. 
Total forms submitted, electronic (in thousands): 540. 

1099-MISC forms submitted by each payer: 10 to 49; 
Number of payers, paper (in thousands): 694; 
Number of payers, electronic (in thousands): 76; 
Total forms submitted, paper (in thousands): 12,954. 
Total forms submitted, electronic (in thousands): 1,491. 

1099-MISC forms submitted by each payer: 50 to 249; 
Number of payers, paper (in thousands): 80; 
Number of payers, electronic (in thousands): 23; 
Total forms submitted, paper (in thousands): 7,338. 
Total forms submitted, electronic (in thousands): 2,712. 

1099-MISC forms submitted by each payer: 250 or more; 
Number of payers, paper (in thousands): 2; 
Number of payers, electronic (in thousands): 20; 
Total forms submitted, paper (in thousands): 712. 
Total forms submitted, electronic (in thousands): 41,625. 

Source: IRS. 

Note: Payers could submit in more than one media. Numbers have been 
rounded and may not total correctly. The threshold mandated for 
electronic submissions is 250 forms. 

[End of figure] 

IRS's four business operating divisions are generally responsible for 
ensuring payers comply with their 1099-MISC reporting requirements. The 
Wage & Investment Division, Tax Exempt and Government Entities Division 
(TE/GE), Large and Mid-Size Business Division (LMSB), and Small 
Business and Self-Employed Division (SB/SE), as a part of their duties, 
conduct examinations of tax returns and documents to verify compliance 
with tax laws. Examinations can include checking payer compliance with 
1099-MISC reporting requirements.[Footnote 15] 

IRS can penalize payers for failing to submit or submitting an 
inaccurate 1099-MISC.[Footnote 16] The penalty is generally $50 per 
information return, increasing to $100 each for intentional payer 
noncompliance of 1099-MISC requirements.[Footnote 17] To encourage 
voluntary reporting compliance, the penalty is $15 (up to a maximum of 
$75,000 per calendar year or $25,000 for small businesses) if the 1099- 
MISC is submitted within 30 days of the due date; $30 (up to a $150,000 
maximum per calendar year or $50,000 for small businesses) if submitted 
after 30 days but by August 1, and $50 (up to a maximum of $250,000 per 
calendar year or $100,000 for small businesses) if submitted after 
August 1 or not at all. IRS will waive the penalty if the payer can 
show "reasonable cause" or if the error or omission does not prevent or 
hinder the IRS from processing the 1099-MISC.[Footnote 18] In IRS's 
fiscal year 2009 budget proposal, the Bush Administration proposed 
increasing the $50 and $100 penalties to $100 and $250 respectively for 
each information return.[Footnote 19] In 2007, we suggested that 
Congress consider requiring IRS to periodically adjust penalties for 
inflation, and round appropriately, the fixed dollar amounts of civil 
tax penalties to account for the decrease in real value over time and 
so that penalties for the same infraction are consistent over time. 
[Footnote 20] 

Payees are responsible for reporting payments they received from payers 
on the appropriate lines of their tax returns.[Footnote 21] Payees are 
also responsible for paying self-employment taxes if they received 
nonemployee compensation. For example, a sole proprietor receiving a 
1099-MISC for nonemployee compensation is to report the payments on 
Schedule C of the 1040 tax return and file Schedule SE to pay the 
associated self-employment taxes. Sole proprietor payees are supposed 
to report 1099-MISC payments as gross receipts and separately report 
their expenses rather than reporting only net amounts. 

Figure 4 shows the automated process IRS uses to detect mismatches 
between nonemployee compensation and other payments reported on 1099- 
MISCs and payees' income tax returns. The Nonfiler program handles 
cases where no income tax return was filed by a 1099-MISC payee. The 
Automated Underreporter (AUR) program handles cases where a payee filed 
a tax return but underreported 1099-MISC payments. AUR's case inventory 
includes payee mismatches over a certain threshold, and IRS has a 
methodology using historical data to select cases for review. AUR 
reviewers manually screen the selected cases to determine whether the 
discrepancy can be resolved without taxpayer contact. For the remaining 
cases selected, IRS sends notices asking the payee to explain 
discrepancies or pay any additional taxes assessed. 

Figure 4: Matching 1099-MISC Reportable Nonemployee Compensation 
Information with Individual Tax Returns: 

[Refer to PDF for image: illustration] 

Central Coast Kite Shop: 
Payer pays $600 to payee for services; 
Payer submits 1099-MISC to IRS; 
Payer sends 1099-MISC copy to payee; 
Payee reports income including 1099-MISC payments on applicable tax 
forms: 
* Form 1040; 
* 1040 Schedule SE; 
* 1040 Schedule C; 
* 1040 Schedule E; 
* 1040 Schedule F; 
Payee files forms to IRS; 
IRS compares information across forms: 
* If income discrepancy is detected: 
- AUR program; 
- IRS send notice to taxpayer; 
* If payers 1099-MISC is present, but no tax return was filed by payee: 
- non-filer program; 
- IRS send notice to taxpayer. 

Source: GAO analysis of IRS information. 

[End of figure] 

According to IRS, third-party information reporting increases voluntary 
tax compliance in part because taxpayers know that IRS is aware of 
their income. For wages and salaries subject to tax withholding and 
substantial third-party information reporting, the percentage of income 
that taxpayers misreport has consistently been measured at around 1 
percent. In contrast, for non-farm sole proprietor income subject to 
little or no third-party reporting, taxpayers misreported more than 
half of such income in 2001, according to IRS's most recent tax gap 
estimates. 

IRS Has Little Information about 1099-MISC Reporting Compliance, but 
Available Evidence Points to the Possibility of a Significant Problem: 

IRS does not have an estimate of 1099-MISC reporting compliance or know 
the characteristics of those payers that fail to comply with the 
reporting requirements. Without an estimate of payers' 1099-MISC 
noncompliance, IRS does not know to what extent such noncompliance 
allows payees to underreport their income without being detected. If a 
large number of payers fail to submit required 1099-MISCs, then the 
resulting decrease in payee tax compliance and lost revenue could be 
large. According to IRS, it is a common misconception among payees that 
they are not required to report payments if they have not received a 
1099-MISC from payers.[Footnote 22] 

IRS has invested significant resources in measuring compliance with 
other aspects of the tax laws. For example, the National Research 
Program (NRP) estimated the compliance rate for individual taxpayers 
for tax year 2001 based on an intensive review of a sample of 46,000 
tax returns. IRS is in the process of completing a new study of the 
rate of tax compliance by individual taxpayers for tax years 2006 and 
2007, and is conducting a similar study of S-corporations.[Footnote 23] 
IRS uses such research to understand where compliance problems are 
greatest and to understand the sources of noncompliance. Armed with 
such understanding, IRS can make better decisions about where and how 
to deploy its resources to address noncompliance. 

Although IRS Does Not Know the Extent of 1099-MISC Payer Noncompliance, 
Available Evidence Points to the Possibility of a Significant Problem: 

Our analysis of 1099-MISC submission patterns by small businesses as 
well as past studies of federal, state and local government agencies 
suggests that payer noncompliance with 1099-MISC reporting requirements 
may be potentially significant. Our analysis of IRS's PMF data for tax 
year 2005 (the last complete year available) showed that, in aggregate, 
8 percent of small businesses (sole proprietorships, and corporations 
and partnerships with assets under $10 million) submitted a 1099- 
MISC.[Footnote 24] As shown in figure 5, over 4 million small 
businesses submitted 1099-MISCs in tax year 2005, and in comparison, 50 
million small businesses filed income tax returns with IRS that same 
year. Results were similar for the three previous years. 

Figure 5: Aggregate Comparison of the Number of Small Businesses Filing 
Tax Returns and Number of Small Businesses Submitting 1099-MISCs, Tax 
Years 2002 to 2005 (in thousands): 

[Refer to PDF for image: vertical bar graph] 

Tax year: 2002: 
Small businesses filing tax returns: 44,571; 
Small businesses submitting 1099-MISCs: 3,873. 

Tax year: 2003: 
Small businesses filing tax returns: 46,095; 
Small businesses submitting 1099-MISCs: 3,966. 

Tax year: 2004: 
Small businesses filing tax returns: 48,501; 
Small businesses submitting 1099-MISCs: 4,088. 

Tax year: 2005: 
Small businesses filing tax returns: 50,075; 
Small businesses submitting 1099-MISCs: 4,198. 

Source: GAO analysis of IRS data. 

Note: IRS defines small businesses, including sole proprietorships, 
partnerships, and corporations, as entities with assets under $10 
million. The number of small business entities filing a tax return with 
IRS came from IRS's Business Master File and Individual Master File; 
the number of small businesses submitting 1099-MISCs came from IRS's 
Payer Master File. 

[End of figure] 

The fact that a relatively low percentage of small businesses submitted 
a 1099-MISC does not indicate on its own that there is a significant 
payer noncompliance problem.[Footnote 25] The many exceptions to the 
general rules for submitting 1099-MISCs along with the payment 
thresholds mean that many small businesses may not be required to 
submit a 1099-MISC. However, if even a small proportion of the almost 
46 million small businesses that did not submit 1099-MISCs in 2005 
improperly failed to report as required, there could be millions of 
missing 1099-MISC information reports. As a consequence, payees could 
have less incentive to voluntarily report that 1099-MISC income on 
their own tax returns if they did not receive a 1099-MISC from the 
payer, and IRS would be unable to detect payee underreporting through 
document matching. Yet, IRS has no idea of the magnitude of payer 
noncompliance and thus the amount of missing 1099-MISCs, as discussed 
above. 

As a proxy for a possible 1099-MISC reporting requirement, we examined 
the 1099-MISC submission rate for Schedule C small businesses that 
reported amounts of $600 or more in contract labor expenses.[Footnote 
26] Based on IRS's Statistics of Income (SOI) data for tax year 2006, 
about 29 percent of Schedule C filers reporting contract labor expenses 
of $600 or more submitted 1099-MISCs.[Footnote 27] Again, we could not 
determine whether the other 71 percent of Schedule C filers reporting 
contact labor expenses over the 1099-MISC reporting threshold were 
noncompliant. Some payers may have amounts under the reporting 
threshold to multiple payees, and other payers may have paid corporate 
payees currently exempt from 1099-MISC reporting. However, some payers 
may have failed to submit 1099-MISCs as required, and IRS does not have 
data to estimate how often this occurs. 

Our 2003 assessment of federal agency compliance with 1099-MISC 
reporting requirements did find significant payer noncompliance. 
[Footnote 28] While most federal agencies in the 14 departments we 
studied submitted information returns as required for calendar years 
2000 and 2001, there were some significant exceptions. Three federal 
departments--Agriculture, Commerce and Justice-- collectively made $5 
billion in payments to 152,000 payees in 2000 and 2001 but did not 
report the payments to IRS on Form 1099-MISCs. In turn, about 8,800 of 
the payees who collectively received payments totaling about $421 
million dollars--an average of about $48,000 each--did not file income 
tax returns for those 2 years.[Footnote 29] 

In June 2007, TIGTA reported that trends in 1099-MISC reporting by 
state and local governments demonstrated potential payer noncompliance 
for tax years 2003 through 2005. For example, while TIGTA found that 
over half of the 81,000 state and local government entities submitted 
1099-MISC forms for each of the 3 years, 30 percent did not submit any 
1099-MISC forms over the period.[Footnote 30] As of December 2008, IRS 
had research planned for fiscal year 2009 to determine whether state 
and local governments that did not submit any 1099-MISCs for tax years 
2003 through 2005 were noncompliant and reasons why they did not 
report. 

Research about Payers' Noncompliance with 1099-MISC Reporting 
Requirements Could Help IRS Target Efforts to Increase Payer Voluntary 
Reporting Compliance: 

Research about the extent and causes of payer noncompliance could help 
IRS develop more effective strategies to increase 1099-MISC 
submissions. Such research would involve costs, but there are options 
for mitigating the costs. IRS might be able to build on current 
research efforts, such as the NRP, or use existing data from the Payer 
Master File. 

Because NRP is already collecting detailed information about small 
business compliance with the rules for reporting receipts and expenses, 
the design of the NRP could be tailored at a relatively low cost to 
assess the extent to which these small businesses submitted 1099-MISCs 
as required. 

In the 2006 and 2007 NRP, IRS is studying whether payers that submitted 
1099-MISCs correctly classified the payees as nonemployees. By 
misclassifying employees as nonemployees, employers could avoid 
withholding taxes as well as paying employment taxes. The 2006 NRP used 
a supplemental questionnaire to collect information on 1099-MISC payer 
reporting for use in assessing misclassification issues. The 2007 NRP 
procedures will direct NRP examiners to more systematically capture 
data about whether small business payers in the NRP sample were 
required to submit information returns--including 1099-MISCs--but did 
not. At this time, IRS has not studied the extent to which payers 
failed to submit 1099-MISCs, but the future NRP results could be useful 
for this purpose.[Footnote 31] 

Another option IRS could explore at a relatively low cost is using PMF 
data to identify businesses that stop reporting or never report 1099- 
MISCs. The PMF data set was used by TIGTA and us in detecting whether 
federal, state, and local governments reported 1099-MISCs. In turn, IRS 
used PMF data to select a sample of state and local governments that 
did not submit any 1099-MISCs for a compliance research project planned 
for fiscal year 2009. To explore small business payer noncompliance, 
IRS could use the PMF data to identify those businesses that submitted 
1099-MISCs in past years but stopped reporting. IRS also could compare 
the PMF population to its master file to identify small businesses that 
never submitted 1099-MISCs, and subsequently conduct research to audit 
a sample of the population to determine whether those not submitting 
1099-MISCs should have. From this type of research, IRS could decide 
how to target particular segments of the payer population (e.g., 
Schedule C filers that report contract labor expenses over $600 or more 
but do not submit 1099-MISCs) for more education and outreach in order 
to reduce payer noncompliance. 

Benefits of 1099-MISC payer compliance research could be significant. 
For perspective, payers reported $6 trillion in 1099-MISC payments for 
tax year 2006, so a one percent increase in reported payments could 
result in an additional $60 billion reported to payees and IRS. 

IRS Efforts to Detect Payers That Fail to Submit 1099-MISC Forms Are 
Uneven: 

Within IRS, TE/GE is active in detecting and pursuing 1099-MISC payer 
noncompliance among federal, state, and local agencies in part so that 
government contractors and vendors cannot evade their tax liabilities. 
[Footnote 32] A TE/GE official said that the division's focus is on 
employer quarterly returns that governmental entities file, as opposed 
to annual income tax returns that the other business divisions examine. 
According to IRS officials, as a part of this resource-intensive focus 
on quarterly returns, TE/GE examiners also scrutinize information 
returns, including 1099-MISCs, that governmental entities file. To 
illustrate the impact that TE/GE's efforts had on detecting 
noncompliance among government payers, IRS audit specialists identified 
and secured over 30,000 additional 1099-MISCs totaling over $522 
million in payments that governmental entities made to payees for tax 
years 2005 through 2007. 

According to IRS officials, TE/GE implemented a "stop filer" program in 
response to our 2003 recommendation that IRS develop a mechanism for 
identifying and tracking federal agencies that fail to submit Form 1099-
MISCs.[Footnote 33] This automated stop filer notice program, which is 
a minimal cost approach compared to other enforcement options for 
detecting possible payer noncompliance, was developed for federal 
agencies that submitted 1099-MISCs one year but not the next. Using PMF 
data, TE/GE issues IRS form 3939 to a federal agency that stops 
submitting 1099-MISCs, asking the agency to provide an explanation. TE/ 
GE officials said they sent over 1,100 stop filer notices for tax year 
2006 to federal entities in August 2008. The officials also said the 
federal agencies' responses to these notices are useful to TE/GE in 
selecting federal agencies for voluntary compliance checks or 
examinations. Servicewide, IRS also uses PMF data to identify payers 
that submit 1099-MISCs late or with missing tax identification numbers 
(TINs). However, IRS does not systematically use the database to 
identify payers with gaps in 1099-MISC reporting history or those that 
never submit the 1099-MISC forms. 

At the time of our review, TE/GE officials stated that numerous 
discrepancies exist in the PMF with the coding for state and local 
governments, and the division is working to correct them. For fiscal 
year 2009, TE/GE plans a 1099-MISC compliance check for a random sample 
of 200 state and local governments that did not submit 1099-MISCs for 
tax years 2003 through 2005.[Footnote 34] Once they have completed this 
activity, they will determine whether sending notices to state and 
local governmental agencies to check for payer noncompliance with 1099- 
MISC reporting requirements is an option they should pursue. 

Another low cost approach that TE/GE officials used is to compile a 
listing of common 1099-MISC payer compliance problems drawn from 
information obtained through examinations and compliance checks. For 
example, government payers sometimes fail to report all payments, or 
submit 1099-MISCs late or with missing payee information. According to 
TE/GE officials we interviewed, their list of common 1099-MISC 
reporting errors is used both to educate examiners on what to look for 
during examinations and reach out to government agencies to help them 
better comply. 

For business taxpayers, IRS policy instructs SB/SE and LMSB examiners 
to determine whether all information returns, including 1099-MISCs, are 
submitted as required and consider internal controls for information 
return reporting. LMSB examiners are to conduct risk analyses of tax 
returns to identify potential noncompliance issues as part of the audit 
planning process. As a result of the risk analysis and in contrast with 
SB/SE practices, LMSB examiners can waive the compliance checks for 
LMSB taxpayers to ensure efficient and effective use of resources. 

Where an examination identifies that a business failed to comply with 
its requirement to submit information returns, including Form 1099- 
MISC, the examiner is to secure the missing information returns. IRS 
could not provide data on how many business examinations detected 
payers that failed to submit 1099-MISCs or how many missing 1099-MISCs 
have been secured by LMSB and SB/SE examiners. While examinations 
primarily focus on income and employment tax liabilities for business 
payers, the examiner also is to consider whether to pursue information 
return penalties depending on the facts and circumstances of the case. 
Improved voluntary compliance by the payer and its payees may justify 
the expenditure of time required to track down the missing 1099-MISCs 
and assess the penalties. However, the maximum penalty is $50 for 
unintentional payer noncompliance and $100 for intentional 
noncompliance for each additional 1099-MISC collected.[Footnote 35] IRS 
has proposed increasing information return penalties to $100 and $250, 
respectively. 

Further, examinations have limitations in that they are costly and 
cover relatively few businesses each year, and thus would not 
necessarily be cost-effective as the sole means to address 1099-MISC 
payer reporting compliance. For example, IRS data show that IRS 
examinations covered less than 1 percent of the 2.2 million tax returns 
that small corporations filed for fiscal year 2007. As we previously 
reported, IRS examined about 3 percent of Schedule C returns in fiscal 
year 2006.[Footnote 36] 

Beyond conducting examinations, which we have described as having 
limitations, IRS does not have an agencywide approach in place to 
identify payers that do not submit 1099-MISC forms. More specifically, 
IRS does not have a stop filer notice program for businesses, as it 
does for federal agencies, to detect 1099-MISC reporting gaps. In 
contrast with the relatively small and stable populations of federal, 
state, and local government payers, the large and shifting population 
of small businesses might challenge IRS in designing a cost-effective 
method for isolating and contacting business payers that do not submit 
1099-MISCs. Given that new businesses start each year while others stop 
operating or merge with other businesses, one approach would be to 
first check to see whether a business filed a tax return before sending 
any notice inquiring about 1099-MISC reporting. While notices are 
likely to provide a more cost-effective approach for pursuing possible 
payer noncompliance compared to examinations, it would be important for 
IRS to test a stop filer program to determine how to target notices to 
businesses. For Schedule C filers for example, a notice program could 
target payers that reported large contract labor expenses but did not 
submit 1099-MISCs.[Footnote 37] Without testing the viability of a 
broader stop filer notice program, IRS could be overlooking a useful 
tool that would help increase 1099-MISC payer compliance. 

Payers Face Impediments in Preparing and Submitting 1099-MISCs, and 
Some Options Could Help Promote Voluntary Reporting Compliance by 
Payers: 

According to IRS officials, IRS advisory groups, and members of the 
1099-MISC community we interviewed, a variety of impediments inhibit 
1099-MISC reporting compliance.[Footnote 38] As a result, some payers 
report erroneous information or fail to submit all 1099-MISCs as 
required. Some payers that do not submit their 1099-MISCs as required 
may be unaware of their 1099-MISC reporting responsibilities. Other 
payers may be confused by various aspects of the 1099-MISC 
requirements. Finally, the inconvenience of submitting 1099-MISCs-- 
whether on paper forms or electronically--may deter compliance. While 
the extent to which these impediments contribute to payer noncompliance 
is unknown, interviewees and others identified options for addressing 
them to promote voluntary compliance. 

Table 1 highlights options based on our analysis and includes options 
we previously reported. We note those options that were proposed by 
IRS, IRS advisory groups, and the National Taxpayer Advocate.[Footnote 
39] Our list of 1099-MISC impediments and options is not exhaustive, 
nor is the list of pros and cons associated with the options. Improved 
IRS guidance and education are relatively low-cost options, but most 
taxpayers use either tax preparers or tax software to prepare their tax 
returns, and may not read IRS instructions and guidance. While taxpayer 
service options may improve compliance for those that are inadvertently 
noncompliant, they are not likely to affect those that are 
intentionally noncompliant.[Footnote 40] Some options to change 1099- 
MISC reporting requirements require legislative action, and other 
options would be costly for IRS to implement. Where the option involves 
particular issues, such as cost or taxpayer burden, we note them in our 
table. 

Table 1: Impediments to 1099-MISC Payer Reporting Compliance and 
Options for Increasing Voluntary 1099-MISC Compliance: 

Some payers are unaware of their 1099-MISC reporting responsibilities: 

Impediments facing 1099-MISC payers: 
1. Some payers are unaware of their 1099-MISC reporting 
responsibilities; 
Options for increasing voluntary compliance and related pros and cons: 
* Add general reminder to Publication 535 Business Expenses to 
highlight 1099-MISC reporting responsibilities; 
* Revise business tax form instructions to remind taxpayers of 1099-
MISC reporting requirements for specific expense types; 
- IRS added a 1099-MISC reminder to the 2007 Schedule C instructions 
for contract labor expenses, and such reminders can be added for other 
1099-MISC reportable expenses such as rent and legal and professional 
services; 
* Target 1099-MISC related education and outreach activities to 
specific payer groups (IRSAC, 2005; IRS Oversight Board, 2008)[A]; 
- IRS has initiated such outreach to federal, state, local and tribal 
governments, but more research is needed to determine which business 
payer groups to target; 
All of the above may be of limited efficacy if taxpayers rely on paid 
preparers and tax preparation software and do not look at IRS 
instructions or guidance, or if taxpayers are willfully misreporting. 
Providing additional guidance could be helpful if tax return 
preparation software is based on the guidance; 
* Increase outreach to paid preparers and tax software vendors to 
promote awareness of 1099-MISC reporting responsibilities (IRSAC, 
2005); 
- Providing 1099-MISC training outreach through IRS's phone forums or 
Nationwide Tax Forums can reach large numbers of paid preparers; 
- Many payers rely on paid preparers and tax software to help them 
comply with their reporting responsibilities; 
* Add check-the-box question to business tax forms requiring taxpayers 
to attest whether they submitted 1099-MISCs related to their reported 
expenses (IRSAC, 2005; National Taxpayer Advocate, 2005); 
- Would force tax preparers and tax software to query taxpayers about 
their expenses, and taxpayers would have to respond to the checkbox 
under penalty of perjury; 
- According to the National Taxpayer Advocate, the burden associated 
with a checkbox asking taxpayers to verify that they have complied with 
existing legal requirements is inherently small; 
- Impact may be on increasing voluntary compliance, with little utility 
as an IRS enforcement tool; 
- California has a similar checkbox on state corporation and S- 
corporation income tax returns, which serves as a reminder to 
taxpayers, as shown below in figure 6. California has not evaluated how 
this reporting feature affects payer reporting compliance; 
* Add a chart in the business income tax instructions to help payers 
determine if they have a potential 1099-MISC reporting requirement and 
need to review the 1099-MISC instructions. IRS frequently provides 
charts and worksheets to help taxpayers understand their filing 
obligations.[B] 

Impediments facing 1099-MISC payers: 
2. Some payers first learn about 1099-MISC reporting responsibilities 
from their tax preparers after 1099-MISC due dates have passed; 
Options for increasing voluntary compliance and related pros and cons: 
* Add IRS's "Information Returns Processing" hyperlink to its "Starting 
a Business" and "Small Business and Self-Employed Tax Center" sites to 
make information reporting a more prominent aspect of business 
responsibilities; 
* Provide a general notice about 1099-MISC reporting responsibilities 
to new small business owners when they apply for an employer 
identification number (EIN); 
- IRS currently encourages online application and provides EINs 
immediately after validation which makes this a low cost option; 
* Provide a notice about 1099-MISC reporting responsibilities, key 
requirements, and due dates to small businesses each fall. Notices 
could be sent to some businesses, such as Schedule C filers reporting 
contract labor expenses for the first time, or all small businesses; 
- Potentially costly mailing. May not be cost-effective if large 
numbers of businesses do not have 1099-MISC reportable payments; 
* Have single due date for 1099-MISC submission to IRS; 
- Change paper submission due date to IRS from February 28 to March 31 
to encourage taxpayers and tax preparers to prepare any 1099-MISCs that 
may have been overlooked without fear of penalty (IRSAC, 2005); 
- Change electronic submission due date to IRS from March 31 to 
February 28 to allow IRS more time to process 1099-MISC for computer 
matching (Electronic Tax Administration Advisory Committee (ETAAC), 
2006); 
- Changing due dates for submitting 1099-MISC to IRS affects due dates 
for other information return series, but does not change the January 
due date to payees; 
* Waive late submission penalties for first-time payers; 
- Some payers that realize they are late in submitting 1099-MISCs may 
choose not to file rather than run the risk of incurring late 
penalties. IRS already reduces the late penalty for 1099-MISCs 
submitted before August 1 to encourage voluntary submissions; 
- Hard for IRS to distinguish first-time payers that may have 
reasonable cause for being late from payers that have willfully 
neglected submit 1099-MISCs. Thus, this option may require legislative 
action to grant IRS authority to automatically waive the late penalty 
for 1099-MISC payers reporting for the first time. 

Some payers are confused about 1099-MISC requirements: 

Impediments facing 1099-MISC payers: 
1. Payers must navigate through 8 pages of singled-spaced instructions 
to determine what to report in the 14 boxes on the 1099-MISC; 
Options for increasing voluntary compliance and related pros and cons: 
* Add a chart in the 1099-MISC instructions for distinguishing 1099-
MISC reportable from non-reportable payments and for calculating 
whether reportable payments reached reporting threshold. For example, 
IRS General Instructions for Forms 1099, 1098, 5498 and W-2g contain a 
chart highlighting what payments and amounts to report for various 
information returns, including Form 1099-MISC; 
* Clarify guidance to address common misreporting errors; 
- IRS does not have research identifying the reasons for payer 
reporting problems. 

Impediments facing 1099-MISC payers: 
2. Payers must determine whether payee is a corporation that is exempt 
from 1099-MISC reporting; 
Options for increasing voluntary compliance and related pros and cons: 
* Change legislation to extend reporting requirements to include 
payments to corporations. We previously reported that the benefits in 
terms of increased revenue and taxpayer compliance exceed costs. In 
1991, we suggested that Congress needed to enact legislation to require 
reporting on payments to corporations but did not formally recommend 
that matter for congressional consideration.[C] IRS agrees that the 
benefits of this option in addressing the tax gap outweigh the costs. 
The Bush Administration requested legislative action in its fiscal year 
2008 and 2009 budgets. According to Treasury estimates, this proposal 
would generate $8.2 billion from 2009 through 2018, due in part to 
increased voluntary compliance and IRS's ability to detect 
underreported payments received by businesses.[D]; 
- The burden of determining the payee's status would be simplified. 
Some payers already submit 1099-MISC for all corporate payees rather 
than determine payee status. (IRSAC, 2005). However, other payers fail 
to submit 1099-MISCs currently required because they mistake small 
business payees as corporations exempt from reporting; 
- Payers need to submit more 1099-MISCs (IRPAC, 2007). Various phase-in 
options could minimize the burden and disruption for payers, such as 
delaying the effective date or initially covering only specific payment 
types, such as rent payments to corporations.[E] 

Impediments facing 1099-MISC payers: 
3. Payers must determine whether payments are reportable due to 
different reporting thresholds. Some payers may underreport 
miscellaneous income types, such as royalties, with thresholds lower 
than $600; 
Options for increasing voluntary compliance and related pros and cons: 
* Add a chart in the 1099-MISC instructions for distinguishing 1099-
MISC reportable from non-reportable payments and for identifying 
whether reportable payments reached reporting threshold. Similarly, 
adding a chart in the business income tax instructions could help 
payers determine if they have a potential 1099-MISC submission 
requirement and need to review the full instructions; 
* Standardize or eliminate dollar threshold for reporting payments 
(NTA, 2005; IRPAC, 2006)[F]; 
* Lower uniform amount (National Taxpayer Advocate, 2005); 
- Increased payer burden to submit more 1099-MISCs; 
- Increased number of 1099-MISCs to IRS for detecting payee income 
underreporting; 
* Higher uniform amount; 
- Decreased payer burden; 
- Decreased number of 1099-MISCs to IRS for detecting payee income 
underreporting; 
* Some options to change the dollar reporting threshold require 
legislative action. 

Impediments facing 1099-MISC payers: 
4. Some payers overlook reporting payments for non-routine or sporadic 
one-time transactions; 
Options for increasing voluntary compliance and related pros and cons: 
* Revise business tax form instructions to remind taxpayers of 1099-
MISC reporting requirements for specific expense types. 

Some payers find 1099-MISC submission burdensome/inconvenient: 

Impediments facing 1099-MISC payers: 
1. Some payers misreport or neglect to report payee taxpayer 
identification numbers (TINs) and could be subject to penalty and 
required to do backup withholding on 1099-MISC payments to payees with 
bad TINS. Some payers misreport 1099-MISCs using the payee's 
partnership's name and TIN rather than the individual payee's Social 
Security Number (SSN); 
Options for increasing voluntary compliance and related pros and cons: 
* Provide education and outreach activities to: 
- Remind payers to secure TINs from payees for 1099-MISC reporting to 
avoid backup withholding for missing or incorrect TINs[G]; 
- Remind payers of IRS's voluntary TIN Matching program that allows 
authorized payers the opportunity to match payee TIN and name with IRS 
records free of charge before submitting the 1099-MISC[H]; 
- Increase awareness of IRS policy on waiving incorrect or missing TIN 
information penalties and how a payer can establish reasonable cause; 
* Require payers to validate payee TINs (IRS, 2007)[I]; 
- Increase reporting burden for payers; 
- Decrease number of 1099-MISCs unmatchable to payees for IRS's 
automated enforcement programs. 

Impediments facing 1099-MISC payers: 
2. Payers submitting paper 1099-MISCs are required to use forms printed 
with special red ink scannable by IRS. IRS does not offer a fillable 
form for downloading on its Web site, and forms computer generated from 
accounting or tax software are not acceptable formats. Some payers 
submit black and white 1099-MISCs anyway; 
Options for increasing voluntary compliance and related pros and cons: 
* Provide an online portal for electronic submission similar to the 
Social Security Administration's portal for W-2s (ETAAC, 2007, 
2008)[J]; 
- Potentially affects a majority of payers as 90 percent of payers used 
paper forms and 64 percent of all payers submitted one to four forms in 
2006; 
- Facilitate more accurate 1099-MISC entry and processing for IRS; 
- Implementation has costs, and IRS currently has no plans for a 1099-
MISC portal; 
* Allow payers to submit computer generated black and white 1099-MISCs 
(IRSAC, 2005); 
- IRS currently has no plans to upgrade its scanning technology to 
eliminate the special red ink requirement and process computer- 
generated black and white 1099-MISCs; 
- IRS submission processing officials said some black and white 
computer-generated forms are currently scanned but require additional 
work to ensure information was correctly scanned. These officials 
predicted that relaxing the red ink requirement would overwhelm the 
current scanning operation. IRS has not conducted any research to 
determine the extent to which computer-generated black and white forms 
slows 1099-MISC processing; 
- Lowering the 250 threshold for electronic submission would reduce the 
total number of paper submissions and might ameliorate such slowdown 
(ETAAC, 2007). Lowering the threshold would require legislative action; 
* Promote awareness of any offers for free electronic 1099-MISC 
submission services available through IRS's authorized e-file partners 
(IRS); 
- A few vendors in the past offered free online preparation and 
submission for small numbers of 1099-MISCs for businesses.[K] 

Impediments facing 1099-MISC payers: 
3. Payers using IRS's Filing Information Returns System (FIRE) must 
register and buy software to format 1099-MISC data transmission, or pay 
a vendor to submit their forms electronically; 
Options for increasing voluntary compliance and related pros and cons: 
Provide an online portal (discussed above); Online portal likely to 
require registration with IRS and may be convenient for payers 
submitting a few forms, but not likely convenient for payers submitting 
250 or more forms. 

Source: GAO analysis. 

[A] IRSAC, Internal Revenue Service Advisory Council Public Meeting, 
November 17, 2005 (Washington, D.C.: Nov. 17, 2005) and IRS, IRS 
Oversight Board, Annual Report 2007, (Washington, D.C.: March 2008). 

[B] For example, the Form 1040 tax return instructions to help 
individuals determine whether they are required to file an income 
return. Also, the Schedule SE highlights who must file the schedule for 
self-employment tax and includes a chart to help individuals determine 
whether to file the short or long Schedule SE. 

[C] GAO/GGD-91-118. In 1992, we recommended federal agencies issue 
information returns on payments to corporations (GAO/GGD-92-130). In 
2004, we reported that revenues from extending reporting requirements 
to corporate payments could increase by billions of dollars (GAO-04-
649). See GAO, Tax Administration: Costs and Uses of Third Party 
Information Returns, GAO-08-266 (Washington, D.C.: Nov. 20, 2007) for a 
list of how the additional costs payers would incur could be mitigated. 

[D] Department of the Treasury, General Explanations of the 
Administration's Fiscal Year 2009 Revenue Proposals (February 2008). 

[E] To minimize burden on small businesses, the National Taxpayer 
Advocate recommended expanding 1099-MISC reporting to include 
corporations only if IRS's National Research Program (NRP) found 
significant levels of noncompliance among small corporations. National 
Taxpayer Advocate, 2007 Annual Report to Congress Vol. 1 Section Two- 
Key Legislative Recommendations, (Washington, D.C.: Jan. 9, 2008). This 
phase-in approach does not simplify the need to track the payee's 
status. 

[F] In 2005 testimony, the National Taxpayer Advocate recommended 
reducing or eliminating the $600 threshold. In 2006, IRPAC recommended 
increasing the medical payment threshold to $5,000 to reduce payer 
reporting burden. 

[G] IRS Form W-9 can be used to obtain and certify the payee's tax 
identification number(TIN). IRS uses the combination of the payee name 
and TIN to match the information reported on a 1099-MISC with 
information reported by the payee on income tax returns. 

[H] Currently, TIN matching is only available to authorized payers that 
filed information returns with IRS in at least one of the two past tax 
years. 

[I] Internal Revenue Service, Reducing the Federal Tax Gap: A Report on 
Improving Voluntary Compliance, (Washington, D.C.: Aug. 2, 2007). 

[J] The Social Security Administration offers free online submission of 
W-2s for payers submitting 20 or fewer forms. 

[K] In 2007, we reported that ,according to vendors we interviewed, 
prices for preparing and submitting 1099-MISCs were relatively low, 
ranging from about $10 per form for 5 forms to about $2 per form for 
100 forms, with one of them charging about $.80 per form for 100,000 
forms. See GAO, Tax Administration: Costs and Uses of Third-Party 
Information Returns, GAO-08-266 (Washington, D.C.: Nov. 20, 2007). 

[End of table] 

Figure 6: California State Tax Forms for Corporations and S 
Corporations, Tax Year 2007: 

[Refer to PDF for image: illustration] 

Two portions of the forms are highlighted: 

2007 California Corporation Franchise or Income Tax Return Form 100 
(page 2): 
Have all required information returns (e.g. federal forms 1099, 5471, 
8300, 8865, etc.) been filed with the Franchise Tax Board? 

2007 California Corporation Franchise or Income Tax Return Form 100 
(page 2): 
Have all required information returns (e.g. federal forms 1099, 8300, 
and state Forms 592, 592-B, etc.) been filed with the Franchise Tax 
Board? 

Source: State of California. 

[End of figure] 

According to our interviewees, multiple approaches could help IRS to 
increase payer compliance with 1099-MISC reporting requirements. For 
some options, such as eliminating the exemption on reporting corporate 
payments, the evidence shows that the benefits outweigh the costs. For 
other options, it is not clear whether the benefits outweigh the 
associated costs. In those cases, additional research by IRS could help 
to evaluate the feasibility of more costly options, such as allowing 
black and white paper 1099-MISCs. Action to move forward on options to 
target outreach to specific payer groups or clarify guidance to reduce 
common reporting mistakes would hinge on IRS first conducting research 
to understand the magnitude of and reasons for payer noncompliance. 

IRS Aims to Improve AUR Efficiency but Lacks a Systematic Process for 
Learning about the Causes of Mismatches: 

Adopting strategies, discussed above, to promote voluntary compliance 
with 1099-MISC reporting requirements and to better monitor payer 
noncompliance would likely increase the number of 1099-MISCs IRS 
receives from payers. This in turn would increase the number of 
automated mismatches identifying potential underreporting by payees. 
However, the AUR program does not pursue all the mismatches from the 
1099-MISCs currently received. Given limited resources for the AUR 
program, it is important for IRS to find ways to more efficiently 
expand AUR coverage and select the best 1099-MISC related cases to 
work. 

While 1099-MISCs constituted 5 percent of all information returns AUR 
used to detect underreporting, a significant portion of the AUR cases 
and assessments were based on 1099-MISC information, as shown in table 
2.[Footnote 41] For tax year 2004 (the last full year available), 19 
percent of 1099-MISC related cases were selected for review, yielding 
21 percent of the additional tax dollars assessed by the AUR program. 
From the 1.9 million 1099-MISC related cases with identified income 
discrepancies, AUR selected a larger proportion (47 percent) for review 
than from the AUR inventory as a whole (31 percent). Over three- 
quarters of all 1099-MISC related cases selected involved nonemployee 
compensation.[Footnote 42] The remaining 1099-MISC related cases 
involve other types of 1099-MISC payments, such as those for rent and 
medical services. For tax year 2004, 1099-MISC related cases in total 
yielded $972 million additional assessments, accounting for 21 percent 
of AUR assessments.[Footnote 43] 

Table 2: 1099-MISC-Related Cases Represent a Significant Share of the 
Cases Selected for AUR Review and Taxes Assessed, Tax Year 2004: 

All AUR cases[A]; 
All Information Returns Submitted (thousands): 1,487,000[B]; 
AUR Case Inventory (thousands): 14,993; 
Cases Selected for AUR review (thousands): 4,645; 
Percent of AUR Inventory Selected: 31.0%; 
Additional Tax Dollars Assessed (millions): $4,673. 

1099-MISC related cases[C]; 
All Information Returns Submitted (thousands): 79,738; 
AUR Case Inventory (thousands): 1,868; 
Cases Selected for AUR review (thousands): 873; 
Percent of AUR Inventory Selected: 46.7%; 
Additional Tax Dollars Assessed (millions): $972. 

1099-MISC Share of all AUR Cases; 
All Information Returns Submitted (thousands): 5%; 
AUR Case Inventory (thousands): 13%; 
Cases Selected for AUR review (thousands): 19%; 
Additional Tax Dollars Assessed (millions): 21%. 

Source: GAO analysis based on IRS data. 

[A] Total information returns used in IRS's computer matching to 
identify the AUR program's inventory of potential mismatches included 
more than 231 million W-2s for employee wages. 

[B] The total number of information returns submitted is only 
significant to the millions. 

[C] The 1099-MISC related cases include nonemployee compensation as 
well as other miscellaneous payments such as for fishing, medical 
services, and crop insurance. 

[End of table] 

IRS's New Soft Notice Initiative Could Increase AUR Program Efficiency: 

AUR currently has a limited reach, pursuing less than half of 1099-MISC 
related cases in its inventory and less than a third of the overall 
inventory for tax year 2004. Attempting to increase AUR program 
efficiency, IRS has pilot tested an automated "soft notice" program 
since 2005. The goal of this program pilot is to increase accurate 
reporting compliance with minimal additional expenditures for IRS. For 
this program pilot, AUR first selected cases from the inventory that 
involved relatively small amounts of money and thus would not have been 
selected for review, and then expanded the pilot to include cases with 
higher-dollar potential tax assessments. The 2,505 cases in the pilot 
test during fiscal years 2005 and 2006 included 550 nonemployee 
compensation cases based on 1099-MISC information. AUR sent letters to 
these taxpayers asking them to either fix the identified discrepancy by 
filing an amended return. However, if the taxpayer's reported income is 
correct, IRS encouraged the taxpayer to contact the third party 
providing the information to IRS. The soft notice is intended to 
educate and promote future compliance, requiring minimal response to 
the notice from taxpayers. 

Based on the pilot, IRS concluded that the soft notice approach 
increased taxpayer compliance, without placing a heavier burden on AUR 
resources to respond to taxpayers' queries. In total for the 2 pilot 
years, 25 percent of taxpayers receiving AUR soft notices filed amended 
tax returns, and 78 percent corrected their reporting behavior in the 
next year's AUR inventory. Less than 13 percent called IRS to inquire 
about the soft notices. With phased rollout slated to begin in fiscal 
year 2009, AUR would be able to achieve a greater coverage over the 
balance of cases in the inventory beyond those selected for AUR review. 
Accordingly, the soft notice approach may be an innovative, cost- 
effective way for IRS to have a greater enforcement presence using 1099-
MISC information. However, it is too early to assess whether the 
effectiveness of the soft notice pilot can be generalized to the AUR 
program overall. For tax year 2007, IRS plans to send about 30,000 AUR 
soft notices across the range of AUR income categories--including about 
4,400 1099-MISC related cases. As of October 2008, IRS plans to collect 
data on taxpayer responses and develop an analysis plan to determine 
which AUR case types are suited for future soft notices. 

IRS Could Use Data on Unproductive 1099-MISC Cases to Better Target 
Case Selection and Provide Service to Reduce Misreporting: 

Some cases AUR selected from its inventory are not productive; that is, 
some cases do not yield any additional tax revenue. About 36 percent of 
the 1099-MISC related cases selected for tax year 2004 were manually 
screened out by AUR reviewers without taxpayer contact. Such cases may 
be screened out because the payee erroneously reports a 1099-MISC 
payment on the wrong tax return line but paid the correct taxes or 
because the discrepancy was because of an IRS error in transcribing a 
paper 1099-MISC. Of the 64 percent of the tax year 2004 1099-MISC cases 
selected that involve taxpayer contact, about 22 percent yielded no 
change in tax assessments. These unproductive cases cost IRS time and 
money that could be spent pursuing other taxpayers who owe additional 
taxes and burden honest taxpayers who must respond to IRS inquiries. A 
case may result in no tax change if a taxpayer responds to the AUR 
notice with information explaining the discrepancy. For example, an 
unproductive 1099-MISC discrepancy may be because the payer reported 
payments made to a partnership under an individual partner's SSN rather 
than under the partnership TIN.[Footnote 44] 

The screen-out process and handling taxpayer contacts are labor- 
intensive for AUR compared with computer processing, so reducing the 
number of unproductive cases would free up resources to work more 
productive cases. IRS officials told us that in fiscal year 2007, IRS 
implemented a new case selection tool using historical data to target 
cases with high assessment potential and that this new methodology has 
yielded progress in terms of increased AUR assessments during fiscal 
year 2008. An additional approach would be to gain insight into the 
source of discrepancies between information reported by payers 
submitting 1099-MISCs and by payees filing tax returns. An 
understanding of the specific causes could help IRS in evaluating its 
matching operations and refining the AUR case selection tool for 1099- 
MISC related cases. Additionally, the information would be useful to 
help IRS target activities to clarify guidance or target outreach to 
educate payers or payees to avoid common reporting errors. 

Currently, IRS does not systematically collect and analyze information 
on the causes of unproductive mismatches that would allow it to 
determine how best to reduce or eliminate such mismatches. The AUR 
management information system has codes showing whether the case was 
closed with or without a tax change, but does not specify how AUR 
accounted for the discrepancy. For example, no change closing codes do 
not specify whether the discrepancy was because of payer misreporting, 
payee misreporting, or IRS error in transcribing paper 1099-MISCs. 
Additionally, IRS does not routinely collect data on the screen-out 
process, so IRS does not have information on the nature and cause of 
recurring 1099-MISC discrepancies. According to AUR officials, the AUR 
program periodically does special analyses to identify how to reduce 
screen-out rates but has not specifically studied 1099-MISC related 
cases. Capturing information on specific reasons why cases were 
unproductive is one approach to improve AUR's efficiency. The 
information would be useful to the AUR program in making informed 
decisions on how to improve the match process and refine its case 
selection methodology for 1099-MISC related cases. 

Moreover, IRS could draw on AUR data to identify common 1099-MISC 
reporting errors and determine how to target service activities to 
improve payer and payee reporting. For example, IRS could avoid some 
unproductive AUR cases by reminding taxpayers doing business as a 
corporation or partnership to provide their business TIN rather than 
their SSNs to payers. Insight about productive AUR cases also could 
help IRS identify opportunities to educate taxpayers on how to avoid 
common mistakes and correctly report 1099-MISC payments. 

Conclusions: 

The 1099-MISCs are a powerful tool through which IRS can encourage 
voluntary compliance by payees and detect underreported income of 
payees that do not voluntarily comply. However, IRS has limited 
knowledge about the extent of payer noncompliance with 1099-MISC 
reporting requirements. If 1099-MISC reporting compliance increased by 
even one percent, it could result in an additional $60 billion of 
payments reported. Without better information about the extent and 
causes of payer noncompliance, IRS has no way of determining if placing 
a heavier emphasis or shifting more resources toward addressing 1099- 
MISC payer noncompliance could lead to an increase in payee voluntary 
compliance and ultimately help reduce the tax gap. 

IRS could make better use of existing data to detect some kinds of 
payer noncompliance. Extending the stop filer notice program used for 
federal payers may be one tool for IRS to reach out to other government 
and business payers that drop off the radar. Developing an estimate of 
payer noncompliance and the characteristics of those payers would be 
key for IRS in developing a cost-effective strategy to identify payers 
that never submit 1099-MISCs. 

Another approach for increasing 1099-MISC reporting compliance is for 
IRS to address the variety of impediments facing payers preparing and 
submitting 1099-MISCs. Eliminating the reporting exemption for payments 
to corporations would ease payer burden associated with first 
determining the status of their payees to identify whether payments are 
reportable. As early as 1991, we determined that the benefits in terms 
of increased tax revenue and voluntary taxpayer compliance would exceed 
the costs of extending 1099-MISC reporting, although we did not 
formally recommend the matter for congressional consideration at that 
time. IRS agrees that the benefits of eliminating the corporate 
exemption outweigh the costs, and the Bush Administration has proposed 
legislative action in its last two budgets. Although it is unclear the 
extent to which taxpayers read guidance on reporting requirements, 
especially taxpayers who use paid preparers, options for additional 
guidance and general reminders are a low cost way to help payers 
understand whether they have a 1099-MISC reporting requirement. For 
other options where it is unclear whether the benefits outweigh the 
associated costs, additional research by IRS could help to evaluate 
whether specific options would be feasible or effective in increasing 
payer compliance. 

In turn, IRS research and other activities aimed at increasing payer 
reporting compliance would likely increase the number of 1099-MISC 
related AUR cases. Reducing the number of unproductive cases would free 
up resources for IRS to handle this increased workload and make better 
use of the 1099-MISC information it receives. 

Matter for Congressional Consideration: 

To simplify the burden that the corporate exemption places on payers to 
distinguish payees' business status and also provide greater 
information reporting, Congress should consider requiring payers to 
report payments to corporations on the form 1099 MISC, as we previously 
suggested and as proposed in the Bush Administration's budget. 

Recommendations for Executive Action: 

We are making eight recommendations to the Commissioner of Internal 
Revenue. 

To gauge the extent of 1099-MISC payer noncompliance and its 
contribution to the tax gap, we recommend that the Commissioner of 
Internal Revenue as part of future research studies: 

* develop an estimate of 1099-MISC payer noncompliance and: 

* determine the nature and characteristics of those payers that do not 
comply with 1099-MISC reporting requirements so that this information 
can be factored into an IRS-wide strategy for increasing 1099-MISC 
payer compliance. 

To increase IRS's ability to detect 1099-MISC payer noncompliance, we 
recommend that the Commissioner of Internal Revenue: 

* test the option of developing a stop filer notice program to target 
business, state, and local entities that submitted 1099-MISC one year 
but did not do so the next. 

To help payers better understand their 1099-MISC reporting 
responsibilities, we recommend that the Commissioner of Internal 
Revenue: 

* add a general reminder to Publication 535 Business Expenses to 
highlight 1099-MISC reporting responsibilities; 

* assess whether adding a checkbox to business tax returns, inquiring 
whether all 1099-MISCs have been submitted, to serve as a reminder to 
payers would help increase 1099-MISC payer compliance; and: 

* include a chart on the Form 1099-MISC as well as business income tax 
instructions for distinguishing reportable from non-reportable payments 
and for calculating whether reportable payments reached the 1099-MISC 
reporting threshold. 

To reduce the submission burden facing many payers each submitting 
small numbers of 1099-MISCs, we recommend that the Commissioner: 

* collect data on the numbers of computer-generated black and white 
1099-MISCs submitted by payers and the labor spent reentering forms 
that cannot be scanned, and evaluate the cost-effectiveness of 
eliminating or relaxing the red ink requirement. 

To help IRS improve its use of 1099-MISC information, we recommend that 
the Commissioner: 

* collect and analyze data on the types of unproductive AUR cases to 
help identify reoccurring errors for use in the AUR case selection 
process and for identifying ways to improve guidance and outreach to 
help payers and payees more accurately report 1099-MISC payments. 

Agency Comments and Our Evaluation: 

In written comments on a draft of this report (which are reprinted in 
appendix II), IRS's Deputy Commissioner for Services and Enforcement 
acknowledged that the evidence in our report indicates that the number 
of 1099-MISCs that payers are required to submit could be much higher 
than what IRS currently receives. IRS agreed with six of our eight 
recommendations. IRS staff provided technical comments that we 
incorporated as appropriate. 

IRS agreed to gather additional data from its ongoing and planned NRP 
studies to determine the extent of 1099-MISC noncompliance. IRS also 
agreed to determine the nature and characteristics of noncompliant 1099-
MISC payers once several years of reporting compliance data are 
available. In addition, IRS agreed to (1) analyze PMF data and develop 
a 1099-MISC stop filer notice test; (2) evaluate the cost effectiveness 
of eliminating or relaxing the red ink requirement; and (3) analyze 
data for a sample of AUR cases to identify opportunities to improve 
case selection and outreach and education for payers and payees. 

IRS disagreed with our recommendation to assess whether adding a 
checkbox to business tax returns would increase 1099-MISC reporting 
compliance. IRS agreed to enhance instructions about 1099-MISC 
reporting requirements to improve voluntary compliance by payers. We do 
not believe this is fully responsive to our recommendation. IRS stated 
that a similar question was removed from the corporate tax return after 
the Paperwork Reduction Act of 1980 was enacted. IRS said that the act 
requires reducing unnecessary burden on taxpayers and prohibits 
collecting information already available. We recognize that the 
Paperwork Reduction Act requires agencies to certify that any 
collection of information avoids unnecessary duplication and is 
necessary for the proper performance of the functions of the agency, 
including whether the information has practical utility. In 
recommending that IRS explore the potential for this option to increase 
1099-MISC reporting, we believe information about the experience of 
California and other states using a similar checkbox query could yield 
insight on how this option could improve payers' reporting compliance 
by reminding payers of their reporting obligations. As discussed in 
this report, many taxpayers rely on tax preparers and tax software and 
may not look at IRS guidance. For this reason, the checkbox option-- 
which we clarified would require taxpayers to respond under penalty of 
perjury--might be more effective because it would force tax preparers 
and software to query taxpayers about their expenses. Further, results 
from the evaluation we recommend could be useful to IRS in revisiting 
its 1981 assessment and weighing the benefits and burdens associated 
with the checkbox option. We clarified in the report that the National 
Taxpayer Advocate has reported that the taxpayer burden associated with 
the checkbox option would be small. 

IRS also disagreed with our recommendation to include a chart in the 
1099-MISC instructions and business income tax instructions. IRS stated 
that the Form 1099-MISC instructions already contain two bulleted lists 
describing which payments are reportable as well as explanations of the 
rules for specific payment types. However, these two lists as well as a 
third bulleted list describing reportable payments to corporations 
include 19 bullet points spanning two pages of the eight pages of 
single-spaced 1099-MISC instructions. We added an example to the report 
citing a chart in IRS's 19-page general instructions that highlights 
what payments and amounts to report on the Form 1099-MISC. We believe 
that the chart approach is an effective way to provide taxpayers with a 
quick guide for navigating the detailed instructions for the Form 1099- 
MISC. For this reason, we continue to recommend adding a chart to the 
1099-MISC instructions and business tax instructions. 

As agreed with your offices, unless you publicly announce its contents 
earlier, we plan no further distribution of this report until 30 days 
from its issue date. At that time, we will send copies to the Chairman 
and Ranking Member, House Committee on Ways and Means; the Secretary of 
the Treasury; the Commissioner of Internal Revenue; and other 
interested parties. This report will be available at no charge on the 
GAO Web site at [hyperlink, http://www.gao.gov]. 

If you or your staff have any questions, please contact me on (202) 512-
9110 or whitej@gao.gov. Contact points for our Offices of Congressional 
Relations and Public Affairs may be found on the last page of this 
report. Key contributors to this report are listed in appendix III. 

Signed by: 

James R. White: 
Director, Tax Issues Strategic Issues Team: 

[End of section] 

Appendix I: Scope and Methodology: 

The objectives of this report were to determine: (1) what IRS knows 
about 1099-MISC reporting noncompliance by payers; (2) how IRS detects 
and pursues 1099-MISC reporting noncompliance by payers; (3) what 
impediments payers encounter in preparing and submitting accurate 1099- 
MISC forms and what options could help IRS address these impediments; 
and (4) what opportunities exist to enhance IRS's use of 1099-MISC 
information to both detect payee noncompliance and promote voluntary 
compliance. 

For background about 1099-MISC reporting requirements, we reviewed laws 
and regulations as well as IRS guidance related to the Form 1099-MISC 
and also spoke with IRS officials. For background about the numbers and 
amounts of payments reported on the 1099-MISC, we obtained information 
reporting program data from Martinsburg Computing Center for tax year 
2006. We also obtained data from IRS's Payer Master File (PMF) on the 
aggregate numbers of payers submitting 1099-MISCs on paper and 
electronically for tax year 2006. We determined that these data were 
sufficiently reliable for our descriptive purposes. 

To determine what IRS knows about the extent of 1099-MISC payer 
noncompliance, we reviewed IRS documents including plans for reducing 
the federal tax gap and National Research Program (NRP) as well as 
budget proposals to expand 1099-MISC reporting.[Footnote 45] Other 
reports we reviewed include past GAO and Treasury Inspector General for 
Tax Administration (TIGTA) reports on 1099-MISC reporting compliance by 
federal, state and local government entities.[Footnote 46] We also 
interviewed NRP officials and staff about research on 1099-MISC 
reporting compliance. 

To obtain perspective on the potential magnitude of payer 
noncompliance, we compared the number of small businesses filing tax 
returns with number of small businesses submitting 1099-MISCs for tax 
years 2002 to 2005. We used IRS's definition of small businesses-- 
businesses entities including sole proprietorships, S-corporations, and 
partnerships with assets under $10 million--under supervision of IRS's 
Small Business and Self-Employed (SB/SE) business operating division. 
We obtained total numbers of small business tax returns submitted in 
these four years from IRS's Business Master File and the Individual 
Master File. For these IRS databases, we relied on the work we perform 
during our annual audits of IRS's financial statements.[Footnote 47] 
While our financial statement audits have identified some data 
reliability problems associated with coding some fields in IRS's tax 
records, we determined that the tax form count data were sufficiently 
reliable to address the report's objectives. We then compared the 
aggregate number of payers identified as small businesses from IRS's 
PMF database to calculate the percentage of small business tax filers 
that submitted 1099-MISCs. The last complete year of payer type 
information available at the time of our analysis was 2005. While we 
could not isolate which businesses were required to submit a 1099-MISC 
but did not, we determined the data were sufficiently reliable to show 
how many small businesses submitted 1099-MISCs to IRS. 

We could not produce a comparable 1099-MISC reporting percentage for 
large corporations and partnerships under supervision of IRS's Large 
and Mid-Size Business (LMSB) business operating division. Large 
businesses may file a consolidated corporate income tax return under 
the parent company's taxpayer identification number (TIN) for all its 
subsidiaries but submit 1099-MISCs under the individual subsidiaries' 
TINs.[Footnote 48] 

To obtain additional perspective on potential 1099-MISC payer reporting 
noncompliance among small businesses, we examined the 1099-MISC 
submission rates for a sample of small business Schedule C filers. 
Contract labor payments to a non-incorporated payee totaling $600 or 
more are reportable on a 1099-MISC, so we used contract labor line on 
Schedule C as proxy for a possible 1099-MISC reporting requirement. We 
included all Schedule C filers that reported $600 or more contract 
labor expenses from IRS's Statistics of Income (SOI) for tax year 2006 
(the last year available).[Footnote 49] We identified the Schedule C 
filers and provided their TINs to IRS. IRS provided data on whether 
these filers submitted a 1099-MISC as indicated on the IRS's 
Information Return Master File. This resulted in 44 percent of the SOI 
sample (unweighted) matching 1099-MISC forms. We then used these 
matches to produce generalizable estimates of Schedule C filers 
reporting $600 or more in contract labor expenses. Using SOI sampling 
weights, we provide the margin of error based on 95 percent confidence 
for our SOI estimate. We determined the SOI results were reliable for 
estimating how many Schedule C filers who reported contract labor 
submitted a 1099-MISC. However, we could not discern whether those that 
did not submit 1099-MISCs had a filing requirement due to the 
exceptions for any payment under $600 and payments to corporations. 

To determine how IRS detects and pursues payer noncompliance with 1099- 
MISC reporting requirements, we reviewed IRS's procedures for checking 
compliance used by IRS's business operating divisions--Tax Exempt and 
Government Entities Division (TE/GE), LMSB, and SB/SE. We also 
interviewed IRS examination and compliance staff from each of these 
divisions. Within TE/GE, we spoke with IRS officials responsible for 
working with federal, state and local government entities as well as 
Indian tribal governments.[Footnote 50] We interviewed IRS officials 
and staff about information returns processing and related penalties. 
Data on IRS's small business examination coverage came from IRS's 
publicly available Data Book. We believe the data were sufficiently 
reliable for the purposes of our review. 

To identify impediments that payers encounter with 1099-MISC reporting, 
options and challenges IRS confronts in addressing these concerns, we 
reviewed IRS and IRS advisory committee reports, previous GAO reports 
as well as those of the National Taxpayer Advocate. Further, we 
reviewed IRS's 1099-MISC form, instructions, and related guidance in 
addition to outreach material used to educate payers about 1099-MISC 
reporting requirements. We interviewed members of IRS advisory groups-
-Electronic Tax Administration Advisory Committee (ETAAC), Information 
Reporting Program Advisory Committee (IRPAC), and Internal Revenue 
Service Advisory Council (IRSAC).[Footnote 51] To obtain perspectives 
from tax preparers and others professionals knowledgeable about 1099- 
MISC payers, we interviewed attendees at IRS's fall 2007 National 
Public Liaison meeting that included members of national stakeholder 
organizations, business and professional associations, tax 
professionals who prepare and submit forms to the IRS, and tax software 
vendors. We also observed IRS's November 2007 National Phone Forum on 
Form 1099-Information Reporting and reviewed IRS's question and answer 
summary provided to participants.[Footnote 52] We also reviewed 
California Franchise Tax Board's corporation and S corporation tax 
return forms and interviewed the California officials about their 
experience with the check-the-box question on the California business 
returns. 

To determine IRS's use of 1099-MISC information, we reviewed IRS 
guidance for 1099-MISC submission processing and the Automated 
Underreporter (AUR) program. We also interviewed IRS's Martinsburg 
Enterprise Computing Center, AUR, and nonfiler program officials and 
staff. We obtained program data on the AUR inventory, case selection, 
and additional dollars assessed for tax year 2004, the last full year 
available in time for this report. The number of information returns 
submitted to IRS came from SOI's Data Book. We determined that the data 
we used were sufficiently reliable for the purpose of our review. 

IRS nonfiler officials stated they are not able to distinguish nonfiler 
income tax return cases that were identified through 1099-MISC 
information from those identified through its stop filer program that 
identifies a gap in a taxpayer's filing of tax returns. Consequently we 
were unable to quantify the extent to which 1099-MISC information is 
used to detect payee nonfiling in the program. 

We conducted this performance audit from June 2007 through January 2009 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

[End of section] 

Appendix II: Comments from the Internal Revenue Service: 

Department Of The Treasury: 
Deputy Commissioner: 
Internal Revenue Service: 
Washington, D.C. 20224: 

January 13, 2009: 

Mr. James R. White: 
Director, Tax Issues: 
United States General Accounting Office: 
Washington, DC 20548: 

Dear Mr. White: 

Thank you for the opportunity to review your draft report entitled "Tax 
Gap - IRS Could Do More to Promote Compliance by Third Parties With 
Miscellaneous Income Reporting Requirements (GAO-09-238)." 

We recognize information reporting by third parties is an important 
tool in addressing the tax gap and agree many of your suggestions will 
assist in promoting voluntary compliance with the miscellaneous income 
(Form 1099-MISC) information reporting requirements. 

For tax year 2006, IRS received over 82 million Forms 1099-MISC from 
third parties, reporting over $6 trillion in payments. However, as your 
report indicates, there is evidence the number required to be filed 
could be much higher. IRS will gather additional data during the on-
going National Research Program (NRP) individual income tax reporting 
compliance studies to stratify the extent of payer noncompliance with 
filing information returns. In our recently completed individual NRP, 
we included several questions related to the filing of information 
returns and imposition of failure to file penalties. Plans are also 
underway for an Employment Tax NRP study. The combined information from 
these NRP studies will provide specific information related to payer 
noncompliance that will be used to refine our efforts to address 
reporting compliance. 

Your report also considered numerous factors influencing the filing of 
Form 1099-MISC. To improve reporting compliance we will 1) enhance our 
instructions to taxpayers regarding appropriate filing of information 
returns, 2) review the requirement to submit information returns using 
specialized red ink, 3) analyze data from the Payor Master File (PMF) 
and, if indicated, implement a test of a Form 1099-MISC Stop Filer 
Program and 4) analyze data from AUR cases to identify opportunities to 
improve selection criteria as well as outreach and education for payers 
and payees. 

The enclosed response addresses each of your recommendations in more 
detail. If you have any questions, please contact Christopher Wagner, 
Commissioner, Small Business/Self-Employed Division at (202) 622-0600. 

Sincerely, 

Signed by: 

Linda E. Stiff: 

Enclosure: 

Recommendation 1: 

Develop an estimate of 1099-MISC payer noncompliance. 

Comment: 

IRS will gather additional data during the on-going individual income 
tax reporting compliance studies. Additional data will be generated by 
an NRP reporting compliance study for employment tax, which is now in 
the planning stages. Data collected from these studies should provide 
valuable information regarding whether service recipients are 
appropriately reporting required payments on Form 1099-MISC. 

IRS researchers will use all of these sources of data to examine the 
extent of Form 1099-MISC payer noncompliance. The individual income tax 
reporting compliance studies are underway for tax year 2006 and 2007. 
Examinations for the employment tax reporting compliance study should 
begin in 2010. The data from employment tax study are expected to 
become available in January 2012. In order to draw reliable 
conclusions, we plan to combine the results from several years of these 
studies 

Recommendation 2: 

Determine the nature and characteristics of those payers who do not 
comply with 1099-MISC reporting requirements so that this information 
can be factored into an IRS-wide strategy for increasing 1099-MISC 
compliance. 

Comment: 

IRS researchers will examine data to determine the nature and 
characteristics of noncompliance among 1099-MISC payers once the 
results from several years of the reporting compliance studies become 
available. 

Recommendation 3: 

Test the option of developing a stop filer notice program to target 
business, state, and local entities that submitted 1099-MISC one year 
but did not do so the next. 

Comment: 

We will analyze data from the Payor Master File (PMF) to determine an 
estimate of the number of filers who filed Form 1099-MISC in tax year 
2005 versus tax year 2006. A team will be formed to develop a stop-
filer test based upon the results of the analysis. The team will 
consist of the various Business Operating Divisions (BODs) where 
significant scope and risk have been determined. 

Recommendation 4: 

Add a general reminder to Publication 535 Business Expenses to 
highlight 1099-MISC reporting responsibilities. 

Comment: 

We agree to adopt this recommendation. 

Recommendation 5: 

Assess whether adding a checkbox to business tax returns, inquiring 
whether all 1099-MISCs have been submitted, to serve as a reminder to 
payers would help increase 1099-MISC payer compliance. 

Comment: 

The question suggested in your report was previously on Form 1120 until 
1980 when it was removed in 1981 due to the enactment of the Paperwork 
Reduction Act (PRA) of 1980. The PRA requires us to reduce unnecessary 
burden on taxpayers and prohibits us from collecting information 
already available from other government sources. However, we agree to 
revise the instructions, where appropriate, to remind taxpayers of 
their reporting obligations. 

Recommendation 6: 

Include a chart on the Form 1099-MISC as well as business income tax 
instructions for distinguishing reportable from non-reportable payments 
and for calculating whether reportable payments reached the 1099-MISC 
reporting threshold. 

Comment: 

The Instructions for Form 1099-MISC contain a bulleted list that 
describes the reportable payments and minimum dollar amount required 
for each payment. The instructions also contain a bulleted list of 
payments not required to be reported and provide explanations of the 
reporting rules for certain types of payments. 

Recommendation 7: 

Collect data on the numbers of computer-generated black and white 1099-
MISCs submitted by payers and the labor spent reentering forms that 
cannot be scanned; and evaluate the cost-effectiveness of eliminating 
or relaxing the magnetic red ink requirement. 

Comment: 

We are unable to collect data on the numbers of computer-generated 
black and white Forms 1099, MISC as we cannot determine which black and 
white forms are computer-generated. Additionally, Forms 1099 are not 
processed by specific type, but are worked as Information Return 
Processing (IRP) documents. 

We will conduct control tests to determine the cost of processing black 
and white versus "red drop-out ink" IRP documents. Testing will begin 
in May 2009 and run through June 2009. By October 15, 2009, we will 
evaluate the cost effectiveness of eliminating or relaxing the "red 
drop-out ink" requirement. 

Recommendation 8: 

Collect and analyze data on types of unproductive Automated 
Underreporter Program (AUR) cases to help identify recurring errors for 
use in identifying ways to improve guidance and outreach to help payers 
and payees more accurately report 1099-MISC payments. 

Comment: 

We will review a sampling of Form 1099-MISC discrepancy cases during 
our AUR annual site visitations and, based on our findings, implement 
needed changes to improve inventory selection and outreach and 
education. 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

James R. White, (202) 512-9110 or whitej@gao.gov: 

Acknowledgments: 

In addition to the contact named above, MaryLynn Sergent, Assistant 
Director; Jeff Arkin; Bertha Dong; Ellen Grady; Leon Green; Shirley 
Jones; Donna Miller; Karen O'Conor; Jessica Thomsen; Cheri Truett; 
James Ungvarsky; Shana Wallace; and John Zombro made key contributions 
to this report. 

[End of section] 

Related GAO Products: 

Tax Gap: Actions That Could Improve Rental Real Estate Reporting 
Compliance. [hyperlink, http://www.gao.gov/products/GAO-08-956]. 
Washington, D.C.: August 28, 2008. 

Highlights of the Joint Forum on Tax Compliance: Options for 
Improvement and Their Budgetary Potential. [hyperlink, 
http://www.gao.gov/products/GAO-08-703SP]. Washington, D.C.: June 2008. 

Tax Administration: Costs and Uses of Third Party Information Returns. 
[hyperlink, http://www.gao.gov/products/GAO-08-266]. Washington, D.C.: 
November 20, 2007. 

Tax Compliance: Inflation Has Significantly Decreased the Real Value of 
Some Penalties. [hyperlink, http://www.gao.gov/products/GAO-07-1062]. 
Washington, D.C.: August 23, 2007. 

Tax Gap: A Strategy for Reducing the Gap Should Include Options for 
Addressing Sole Proprietor Noncompliance. [hyperlink, 
http://www.gao.gov/products/GAO-07-1014]. Washington, D.C.: July 13, 
2007. 

Tax Compliance: Multiple Approaches Are Needed to Reduce the Tax Gap. 
[hyperlink, http://www.gao.gov/products/GAO-07-488T]. Washington, D.C.: 
February 16, 2007. 

Opportunities for Congressional Oversight And Improved Use of Taxpayer 
Funds: Budgetary Implications of Selected GAO Work. [hyperlink, 
http://www.gao.gov/products/GAO-04-649]. Washington, D.C.: May 4, 2004. 

Tax Administration: More Can Be Done to Ensure Federal Agencies File 
Accurate Information Returns. [hyperlink, 
http://www.gao.gov/products/GAO-04-74]. Washington, D.C.: December 5, 
2003. 

Tax Administration: Federal Agencies Should Report Service Payments to 
Corporations. [hyperlink, http://www.gao.gov/products/GAO/GGD-92-130]. 
Washington, D.C.: September 22, 1992. 

Tax Administration: Benefits of a Corporate Document Matching Program 
Exceed the Costs. [hyperlink, 
http://www.gao.gov/products/GAO/GGD-91-118]. Washington, D.C.: 
September 27, 1991. 

[End of section] 

Footnotes: 

[1] See generally 26 U.S.C. §6041 and §6041A. §6041 requires 
information reporting for payments made in the course of a trade or 
business to another person such as for rent, salaries, compensation, 
etc. §6041A relates to returns regarding payments of remuneration for 
services and direct sales. 

[2] The gross tax gap--$345 billion in 2001 according to IRS's latest 
estimate--is the annual difference between what taxpayers should have 
paid and what they voluntarily paid on time. IRS estimated that it 
would eventually recover around $55 billion of the 2001 tax gap through 
late payments and IRS enforcement actions, leaving a net tax gap of 
$290 billion. 

[3] GAO, Tax Gap: A Strategy for Reducing the Gap Should Include 
Options for Addressing Sole Proprietor Noncompliance, [hyperlink, 
http://www.gao.gov/products/GAO-07-1014] (Washington, D.C.: July 13, 
2007). 

[4] GAO, Tax Administration: More Can Be Done to Ensure Federal 
Agencies File Accurate Information Returns, [hyperlink, 
http://www.gao.gov/products/GAO-04-74] (Washington, D.C.: Dec. 5, 
2003). 

[5] Treasury Inspector General for Tax Administration, More Complete 
and Accurate Data are Needed to Assess the Impact of Actions to Address 
Compliance Reporting of State and Local Government Entities (Reference 
No. 2007-10-081, June 8, 2007). 

[6] The last complete year of payer type data available for our 
analysis was tax year 2005. 

[7] Some rent payments of at least $600, other than those paid to real 
estate agents, are also reported on the 1099-MISC. Treasury Regulations 
§1.6041-3(d.). See GAO, Tax Gap: Actions That Could Improve Rental Real 
Estate Reporting Compliance, [hyperlink, 
http://www.gao.gov/products/GAO-08-956] (Washington, D.C.: Aug. 28, 
2008). 

[8] Internal Revenue Service, 2007 Instructions for Form 1099-MISC 
(revised April 2007). 

[9] Boxes 11 and 12 currently are not used to report payments. 

[10] Nonemployee compensation is payment for labor or services to an 
individual a business does not officially employ. The nonemployee box 
also includes attorney fees paid to legal corporations as well as 
federal executive agency payments to corporate vendors. 

[11] Internal Revenue Service, General Instructions for Filing Forms 
1098, 1099, 5498, and W-2G, 2007. 

[12] IRS uses the Service Center Recognition Image Processing System 
(SCRIPS) to capture printed or handwritten information from paper forms 
and convert the information into machine-readable format for computer 
processing. 

[13] 26 U.S.C. § 6011(e)(2)(A). 

[14] Figure 3 does not include data for magnetic submissions. IRS is 
phasing out magnetic submissions after December 31, 2008. See Internal 
Revenue Service, Publication 1220 Specifications for Filing Forms 1098, 
1099, 5498, and W-2G Electronically (June 9, 2008). 

[15] IRS generally defines large and mid-size corporations and 
partnerships as those with assets over $10 million. Small businesses 
are those with assets under $10 million, including sole 
proprietorships. 

[16] 26 U.S.C. § 6721. 

[17] 26 U.S.C. § 6721 provides for lower maximum penalties for small 
businesses with average annual gross receipts of $5 million or less for 
the 3 most recent tax years (or for the period in existence if shorter) 
ending before the calendar year in which the information returns were 
due. 

[18] 26 U.S.C. § 6724. 

[19] The administration estimated that this proposal would generate 
$391 million over the next ten years. 

[20] GAO, Tax Compliance: Inflation Has Significantly Decreased the 
Real Value of Some Penalties, [hyperlink, 
http://www.gao.gov/products/GAO-07-1062] (Washington, D.C.: Aug. 23, 
2007). 

[21] Payments that are not reportable on 1099-MISC may, nonetheless, be 
taxable to the payee, and payees must report all income to IRS on their 
income tax returns. 

[22] Internal Revenue Service, "Reporting Miscellaneous Income" Fact 
Sheet, FS-2007-26, November 2007. 

[23] An S-corporation is a corporation with a limited number of 
shareholders (100 or fewer) that is not taxed as a regular corporation 
and meets certain other requirements. According to IRS, this is the 
most common corporate entity. 

[24] Even among the 8 percent submitting 1099-MISCs, some small 
business payers submitted their 1099-MISCs late or missing key payee 
information, and some may have failed to submit 1090-MISCs for some 
reportable payments. Below we discuss impediments facing payers in 
preparing and submitting Form 1099-MISCs to IRS. 

[25] The difference between large businesses filing tax returns and 
submitting 1099-MISCs is much smaller as large businesses may file 
consolidated income tax returns while submitting information returns 
under individual subsidiaries. 

[26] Beginning in tax year 2007, IRS instructions specify that expenses 
reported on the Schedule C contract labor line may be reportable on the 
1099-MISC. 

[27] For the SOI sample estimate of 28.9 percent, we are 95 percent 
confident that the actual estimate is between 27.3 and 30.5 percent. 

[28] [hyperlink, http://www.gao.gov/products/GAO-04-74]. 

[29] At the time, IRS did not have a program to identify and follow-up 
with federal agencies that did not submit information returns. IRS 
activities to monitor federal compliance with 1099-MISC reporting 
requirements in response to our 2003 recommendations are discussed 
later in this section. 

[30] Government audits, such as in New York City and Detroit, confirm 
that some local agencies did not always report 1099-MISCs as required. 
City of New York, Office of the Comptroller, Audit Report: Follow-up 
Audit on the Financial and Operating Practices of the Queens County 
Public Administrator, MD06-057F, April 24, 2006; and City of Detroit, 
Office of the Auditor General, Follow-up Audit of the Law Department, 
July 2005-June 2007. 

[31] NRP data with 2006 and 2007 results will be available in late 2009 
and late 2010, respectively. 

[32] IRS can check for payer compliance with 1099-MISC reporting 
requirements through examinations and voluntary compliance checks. An 
examination may involve an in-depth review of an entity's tax records, 
and identifying tax discrepancies or an additional tax liability. A 
compliance check involves contact with the entity or individual, but is 
more limited in its scope, because it does not involve determining a 
tax liability. An entity has the right to decline to participate in a 
compliance check. 

[33] In [hyperlink, http://www.gao.gov/products/GAO-04-74], we found 
that IRS did not have a mechanism for identifying and tracking federal 
agencies that failed to file Forms 1099-MISCs for vendor payments. One 
of our recommendations was that IRS establish such a program. 

[34] The sample was selected from over 23,000 state and local agencies 
which were identified by TIGTA as not submitting any 1099-MISCs and not 
subject to any previous compliance check by TE/GE. 

[35] If a payer submitted 1099-MISCs with missing TINS and was 
previously directed by IRS to begin backup withholding for the payees 
without TINS, the payer can be held liable for amounts of backup 
withholding not withheld from those payees. 

[36] [hyperlink, http://www.gao.gov/products/GAO-07-1014]. 

[37] Whereas the SOI sample dataset we used in our Schedule C analysis 
included contract labor expense information, IRS currently does not 
transcribe the contract labor expense line for all Schedule Cs filed. 

[38] IRS advisory groups include Electronic Tax Administration Advisory 
Committee (ETAAC), Information Reporting Program Advisory Committee 
(IRPAC), and Internal Revenue Service Advisory Council (IRSAC). We also 
interviewed tax professionals, tax software vendors, paid preparers, 
and other business and professional association representatives 
knowledgeable about 1099-MISC payer reporting attending the IRS 
National Public Liaisons (NPL) fall 2007 meeting. 

[39] The table notes options specifically recommended by IRS's advisory 
groups or by IRS in its budgets and tax gap plans. 

[40] GAO, Highlights of the Joint Forum on Tax Compliance: Options for 
Improvement and Their Budgetary Potential, [hyperlink, 
http://www.gao.gov/products/GAO-08-703SP] (Washington, D.C.: June 
2008). 

[41] The 1099-MISC related cases include eight of over 60 AUR 
categories: (1) nonemployee compensation of 50 percent or more of the 
taxpayer's income (2) nonemployee compensation with fishing income 
where the tax change was 80 percent or greater than the original tax 
reported, (3) fishing income, (4) rents and royalties), (5) medical 
payments, (6) other income, (7) payments in lieu of dividends, and (8) 
crop insurance. 

[42] Nonemployee compensation cases include those where 50 percent or 
more of the taxpayer's income was nonemployee compensation or where the 
tax change was 80 percent greater than the original tax reported. 
Nonemployee compensation cases can yield both income and self- 
employment tax assessments and accounted for 91 percent of additional 
assessments from 1099-MISC related cases for tax year 2004. 

[43] Additional AUR assessments include total assessments recommended 
for taxes and associated penalties net of any refunds. Amounts of 
recommended assessments could be abated in appeals or may not be 
collected, and thus should not be construed as amounts ultimately 
collected. 

[44] A case also may result in no tax change if, for example, the payee 
incorrectly reported net income instead of reporting the full 1099-MISC 
payment and associated expenses. 

[45] Internal Revenue Service, Reducing the Federal Tax Gap: A Report 
on Improving Voluntary Compliance, (Washington, D.C.: Aug. 2, 2007). 

[46] See GAO, Tax Administration: More Can Be Done to Ensure Federal 
Agencies File Accurate Information Returns, [hyperlink, 
http://www.gao.gov/products/GAO-04-74] (Washington, DC: Dec. 5, 2003) 
and Treasury Inspector General for Tax Administration: More Complete 
and Accurate Data are Needed to Assess the Impact of Actions to Address 
Compliance Reporting of State and Local Government Entities (Reference 
No. 2007-10-081, June 8, 2007). 

[47] GAO, Financial Audit: IRS's Fiscal Years 2008 and 2007 Financial 
Statements, [hyperlink, http://www.gao.gov/products/GAO-09-119] 
(Washington, D.C.: Nov. 10, 2008). 

[48] For large businesses, subsidiaries with over 80 percent of its 
control under its parent company have the option of filing income tax 
under its parent company using a consolidated corporate income tax 
return. 

[49] SOI is a widely used IRS research database. The SOI files are a 
stratified probability sample of unaudited income tax returns. Data 
analysis results using SOI are subject to imprecision owing to sampling 
variability. 

[50] We did not address 1099-MISC payer reporting compliance by tax- 
exempt organizations, such as chartable organizations and foundations, 
or employee retirement plans. 

[51] All three IRS advisory groups provide a public forum for 
discussions between IRS officials and representatives of the public. 
ETAAC advises on IRS's electronic tax administration activities. IRPAC 
advises on improving information reporting, while IRSAC advises on 
emerging tax administration challenges and the perspectives of specific 
tax payer segments. 

[52] IRS offered three sessions of its free 1099-MISC phone training 
for tax practitioners, businesses, government agencies, and other 
interested parties. Participants could ask questions during the 
sessions or submit their questions by email for IRS to answer. 

[End of section] 

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