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COMMERCE BUSINESS DAILY ISSUE OF JULY 18,1997 PSA#1890DEPARTMENT OF THE TREASURY, Internal Revenue Service, (M:P), 6009 Oxon
Hill Road, Suite 700, Oxon Hill, MD 20745 R -- ASSISTANCE TO DEFINE AND MEASURE TAXPAYER BURDEN SOL
CBD&&&97060001 DUE 072597 POC Contract Specialist, William Pinkston,
Faxs 202/283-1514 The Internal Revenue Service (IRS) is considering
contracting for assistance to define and measure taxpayer burden.
Sources are sought to provide information on their capabilities and
technologies currently available in the market. This information will
be used to develop a precise statement of work. In performing its
mission, IRS attempts to ensure compliance with the tax laws at the
lowest possible cost. A key element of the overall cost of the tax
system is the cost imposed on taxpayers: setting up and maintaining
records, preparing returns, waiting for refunds, responding to
inquiries regarding the return, etc. The tax system's "burden" cost,
which includes both taxpayer time and out-of-pocket costs, is as real
as the IRS budget cost of processing taxpayer returns or conducting
audits. In keeping with this perspective, the IRS Strategic Plan and
Budget states that reducing taxpayer burden is a primary corporate
objective. To perform its mandate effectively, the IRS must have an
unambiguous definition of taxpayer burden and a practical, objective
means to measure and monitor it. The following sections discuss (1)
specific concerns IRS has with its current measure of taxpayer burden,
(2) the current IRS definition of taxpayer burden and what might be
included in a new burden measure, and (3) the functional requirements
of a new IRS measure of taxpayer burden. Concerns with Current IRS
Measure of Taxpayer Burden The Service's current measure of taxpayer
burden was developed to comply with the Paperwork Reduction Act (PRA)
of 1980. The measure, developed with the assistance of Arthur D.
Little, Inc., is based on taxpayer survey data from 1984. For tax forms
subject to PRA, the measure estimates the average time taxpayers spend:
(1) keeping records; (2) learning about tax law; (3) preparing tax
forms; and (4) copying, assembling, and sending tax forms to IRS.
Although ADL was an improvement over IRS s previous burden measure, it
has a number of weaknesses: Burden is measured in hours, not dollars:
A fundamental shortcoming of the ADL model is that burden is measured
in hours of taxpayer time, not in dollars. Because the IRS's budget
and the revenue it collects are counted in dollars, it is difficult to
make budget and revenue tradeoffs with taxpayer burden. ADL covers
only tax form burden: Because it was developed to measure the paperwork
burden of tax forms and regulations subject to PRA, the ADL model does
not cover the burden resulting from IRS enforcement or customer
service activities like audits, collections, refunds, phone calls, etc.
Outdated estimates: Although the ADL model permits IRS to update burden
estimates to reflect changes in tax forms and taxpayer filing habits,
the 1984 survey data used to the construct the model may no longer be
relevant. Furthermore, with the numerous changes in tax laws and the
increased use of computers and tax preparation software since the
mid-1980's, the underlying assumptions in ADL may not be valid.
Defining Taxpayer Burden IRS currently defines burden as the time,
expense, and dissatisfaction taxpayers experience in complying with
their tax obligations. In the abstract, taxpayer burden includes all
costs, explicit or implied, of understanding the tax laws, completing
and filing the tax return, maintaining the records necessary to comply,
responding to any IRS requests for clarification, etc. Although the
conceptual definition of burden seems straightforward, a good deal of
confusion and debate still exist on what aspects of tax system cost
should be included in models attempting to measure taxpayer burden. For
example: Dissatisfaction & psychic burden: Is it practical for IRS to
measure explicitly the dissatisfaction costs of compliance? For
example, if the value of time spent in tax preparation (burden) is
specified as the amount one would have to be paid to prepare someone
else's tax return, all costs would be captured and a separate
dissatisfaction category, even if measurable, would be unnecessary.
Statutory vs. administrative burden: Is it possible to develop
objective estimates of the portion of taxpayer burden attributable to
tax law versus the portion attributable to tax administration, for
which IRS is responsible? Compliant vs. non-compliant taxpayer burden:
Should IRS identify and differentiate between burden placed on
compliant taxpayers, inadvertently non-compliant taxpayers, and
tax-evading non-compliant taxpayers? Requirements of a New Taxpayer
Burden Measure An efficient tax system will attempt to (1) minimize the
total costs associated with collecting a tax dollar or (2) maximize
legitimate taxes collected for a given cost. Under either strategy, the
IRS must measure the total taxpayer burden cost of the tax system and
identify tradeoffs between burden and budget costs that improve the
efficiency of the tax system. Therefore, a new measure of taxpayer
burden should have the following attributes: * Measure the total
taxpayer burden cost of the Federal income tax system, including burden
from tax forms, IRS enforcement efforts, and customer service
activities; * Measure burden both in time and in dollars so that IRS
burden reduction initiatives can be evaluated on their budget and
revenue impact; * Measure the burden impact of fundamental changes to
the tax code; * Measure the burden impact of significant changes in tax
administration, such as converting to a system in which all tax returns
and tax payments are processed electronically; * Measure the burden
impact of changes in IRS operations, such as increased toll-free
assistance, Internet access to IRS forms and publications, and shorter
refund cycle times; * Measure burden for different groups of taxpayers
(e.g., individual, self-employed, retired, small-business, large
company, etc.); * Measure the impact of a wide range of programs so IRS
can evaluate and compare the taxpayer burden impact of current policies
and planned initiatives; and, * Use information for measuring burden
that can be updated each year easily and cheaply. Please annotate
whether your firm is a large, small, or disadvantaged business under
SIC 8721, size standard of $6 million in annual receipts. NOTE: This is
for planning purposes ONLY. There is no Request for Proposals at this
time. No oral communication shall be accepted. Questions and/or
responses pertaining to this announcement may be faxed to the
individual listed above. (0197) Loren Data Corp. http://www.ld.com (SYN# 0112 19970718\R-0020.SOL)
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