Income Tax Compliance Costs

National Tax Journal, December 2013, 66 (4), 833–854

http://dx.doi.org/10.17310/ntj.2013.4.03

INCOME TAXES AND COMPLIANCE COSTS:
HOW ARE THEY RELATED?
Rosemary Marcuss, George Contos, John Guyton, Patrick Langetieg,
Allen Lerman, Susan Nelson, Brenda Schafer, and Melissa Vigil

This paper examines the relationship between tax complexity and income tax compliance costs through the development and use of econometric models based on a mix
of survey and tax administration data. The models are used to analyze compliance
cost differences in taxpayer characteristics and return complexity.
Keywords: compliance burden, compliance cost, complexity
JEL Codes: H24, H25

I. INTRODUCTION

T

he three pillars of tax policy, commonly juxtaposed in discussions of tax reform, are
equity, efficiency, and simplicity. This paper focuses on the third pillar, simplicity,
by offering insights into its antithesis, complexity, and the ways that complexity affects
taxpayer compliance costs.
The U.S. tax system is complex and imposes compliance costs on taxpayers. We estimate that the annual income tax-related compliance costs exceed $150 billion, at least
$50 billion for individuals and $100 billion for businesses, or a little over 10 percent of
Rosemary Marcuss: IRS Research, Analysis, and Statistics, Washington, DC, USA (Rosemary.D.Marcuss@irs.gov)
George Contos: IRS Research, Analysis, and Statistics, Washington, DC, USA (George.Contos@irs.gov)
John Guyton: IRS Research, Analysis, and Statistics, Washington, DC, USA (John.Guyton@irs.gov)
Patrick Langetieg: IRS Research, Analysis, and Statistics, Washington, DC, USA (Patrick.T.Langetieg@irs.gov)
Allen Lerman: Ofce of Tax Analysis, U.S. Department of the Treasury, Washington, DC, USA (Allen.Lerman@
treasury.gov)
Susan Nelson: Ofce of Tax Analysis, U.S. Department of the Treasury, Washington, DC, USA (Susan.Nelson@
treasury.gov)
Brenda Schafer: IRS Research, Analysis, and Statistics, Washington, DC, USA (Brenda.Schafer@irs.gov)
Melissa Vigil: IRS Research, Analysis, and Statistics, Washington, DC, USA (Melissa.Vigil@irs.gov)

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federal income tax revenue.1 2 A better understanding of the relationship between federal
income taxes and taxpayer compliance burden can inform tax law simplification efforts
and reveal other opportunities for mitigating compliance costs. To that end, we discuss
how tax complexity and other factors affect the compliance burden, the measurement
of taxpayer burden via surveys, the development of the Internal Revenue Service (IRS)
individual and business burden models, and how those models are used to estimate and
analyze compliance burden.
II. COMPLEXITY AND COMPLIANCE BURDEN
A. Increasing Tax Code Complexity
According to the National Taxpayer Advocate’s Annual Report to Congress (2012),
complexity is the main issue faced by taxpayers and the IRS. That report also states
that there have been about 4,680 changes to the tax code since 2001.
Even provisions intended as tax simplification may actually expand the tax code and
result in tangential complexity due to exceptions to the new rules, phased-in implementation, and interactions with other provisions. Using the number of Internal Revenue
Code (IRC) subdivisions (subtitles, parts, sub-parts, etc.) and cross references as a
proxy for tax complexity, Figure 1 below indicates how tax complexity has increased
for tax years 1991 through 2012.3
B. Complexity and Increasing Use of Assisted Tax Preparation Methods
Citing complexity as the reason, the Taxpayer Advocate states that “. . . few taxpayers
complete their returns without assistance” (National Taxpayer Advocate, 2012, p. v).
As the tax code becomes more complex, it would follow that more taxpayers would
opt for an assisted tax preparation method. Figure 2 shows that the use of assisted tax
preparation methods, including self-preparation with tax software, has indeed increased
over the years.
Our research indicates that tax complexity does play a role in the decision to use
an assisted method. However, we suggest that other factors may actually be greater
contributors to the migration from pen and paper tax self-preparation. For example,
many taxpayers with basic income reporting requirements (income solely from wages,
interest, or unemployment benefits) tend to use an assisted method if they are getting
1

2

3

This percentage is similar to an earlier estimate by Slemrod (1996). These estimates are lower bounds
because they exclude taxpayer burden related to information reporting and income tax withholding.
Because compliance costs of flow-through entities are included as business compliance costs whereas much
of the tax on flow-through income is paid at the individual level, it is difficult to compute an appropriate
ratio of compliance costs to tax revenues separately for individuals and businesses.
All figures are preliminary and subject to revision.

Income Taxes and Compliance Costs: How Are They Related?

835

Figure 1
Number of IRC Sections, Subsections, and Cross References
80,000
70,000
60,000
50,000
40,000
30,000
20,000
10,000

19

9
19 1
9
19 2
9
19 3
9
19 4
95
19
9
19 6
9
19 7
9
19 8
99
20
00
20
01
20
0
20 2
03
20
04
20
0
20 5
06
20
0
20 7
0
20 8
0
20 9
10
20
11
20
12

0

Year

a refund (Figure 3). This finding is plausible since software-prepared returns (whether
prepared by the taxpayer or a paid professional) are generally filed electronically, which
speeds up the refund process.
In addition, several other factors are likely to contribute to the choice to use an assisted
method, including increasing technology adoption, increased availability of free online
tax preparation services, and the assurance that all required forms and schedules are
filed with the return and the math is correct. These influences can be seen in the fact that
even taxpayers filing a simple return with no refund are increasingly using an assisted
method as well (Figure 4).
Tables 3 and 4 suggest that many taxpayers are substituting out-of-pocket costs for
their time. To determine the extent to which this trade-off may be affecting compliance
costs, we reviewed average tax preparation fees from 1995–2010.4 Figure 5 shows that tax
preparation fees have remained roughly constant over the past decade in real dollar terms.
4

The tax preparation fee deduction is claimed on Schedule A before the 2 percent of AGI limitation. Source:
SOI Statistical Tables, Table 3, “Returns with Itemized Deductions: Itemized Deductions by Type and by
Size of Adjusted Gross Income,” http://www.irs.gov/uac/SOI-Tax-Stats-Individual-Tax-Statistics.

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Figure 2
Percent of Income Tax Returns Prepared Using Assisted Methods
100
90
80
70
60
50
40
30
20
10
0
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012
Year
Total Assisted

Paid Prepared

Self-Prepared
with Software
Assistance

In light of technology diffusion and the role that electronic filing plays in expediting
refunds, we find only limited support for the premise that increasing tax code complexity
is a primary driver of the expanding use of assisted preparation methods. Technology
likely plays a large role in mitigating the impact of increasing tax law complexity by
determining which provisions apply to the taxpayer via the tax interview, providing new
or updated tax forms, performing calculations, and facilitating planning.
C. Complexity Does Not Afect Taxpayers Equally
The bulk of the impact of an increase in complexity falls on the taxpayers who are
affected by the change. For example, a change in the foreign earned income exclusion
rules likely has little or no impact on a taxpayer that never earns income in a foreign

Income Taxes and Compliance Costs: How Are They Related?

837

Figure 3
Percent of Individual Returns with a Refund Using Assisted Preparation
Methods
100
90
80
70
60
50
40
30
20
10
0
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012
Year
Basic Returns

Other Returns

country, but can have a significant impact on a taxpayer who does. Although the former
taxpayer may have an information-gathering cost to figure out what “foreign earned
income” is and if the new rules apply to him, actually claiming a foreign earned income
exclusion is far more burdensome. Further, the use of tax software or a tax preparer
may decrease the time spent by the taxpayer on this type of information gathering and
therefore reduce the effect of this increased complexity.
III. MEASURING COMPLIANCE COSTS
As a key step in estimating taxpayer compliance costs, the IRS conducts taxpayer
burden surveys that gather statistically representative data regarding the time and outof-pocket costs incurred by taxpayers in response to their tax obligations. Individual
Taxpayer Burden (ITB) surveys have been conducted for tax years 1984, 1999, 2000,

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Figure 4
Percent of Individual Returns Without a Refund Using Assisted Preparation
Methods
100
90
80
70
60
50
40
30
20
10
0

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012
Year
Basic Returns

Other Returns

2007, and 2010. Similar Business Taxpayer Burden (BTB) surveys for corporations
and partnerships were conducted for tax years 2004 and 2009. This paper focuses on
the results from the 2010 ITB and 2009 BTB surveys and related research.
The sampling methodology for the ITB 2010 survey involved a stratified random
sample with 15 categories. Returns were first distinguished by preparation method
(third-party prepared, self-prepared using tax preparation software, and self-prepared
by hand). Returns were further stratified within the three preparation categories based
on five complexity categories: low, low-medium, medium, high-medium, and high.5
The 2010 ITB survey consisted of several framing questions, such as asking the taxpayer to think about resources they may have used when preparing their return, as well
5

Appendix A provides more information on the five complexity categories.

Income Taxes and Compliance Costs: How Are They Related?

839

Figure 5
Average Tax Preparation Fee Deduction Reported on Schedule A
for Taxpayers Using a Paid Preparer ($2010)
350
300
250
200
150
100
50
0
1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010
Year

as the key time and out-of-pocket cost questions. These topics were broken down into
two separate response items: (1) time, including recordkeeping, tax planning, gathering
materials, and completing and submitting the tax return; and (2) out-of-pocket costs,
including paid preparer services, tax preparation website or software, fees for early or
immediate refund, tax books, classes, or seminars, and postage or filing fees.
Data collection for 2010 ITB occurred between September 9, 2011, and May 31, 2012.
To reduce recall bias, the surveys were conducted close to when the taxpayers filed
their tax returns. The IRS contracted with an outside vendor to administer the surveys.
The overall response rate was 42 percent after adjusting for unreachable taxpayers.
The 2009 BTB updated the small business taxpayer burden survey of 2004 and
added large businesses. Previous studies of compliance burden for large businesses
were conducted in 1993 by Slemrod and Blumenthal (1996) and in 2002 by Slemrod
and Venkatesh (2002). In addition, the 1986 Arthur D. Little study for Tax Year 1984
also covered business taxpayers, as discussed in Contos, et al. (2012).
As with the 2010 ITB, stratified random sampling was used. Business entities were
grouped by entity type based on the tax return they filed (corporation, S corporation, or
partnership). Each entity type was distinguished by preparation method: self-prepared

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(no paid preparer signature) and third-party prepared. Self-prepared returns were divided
into four income categories and third-party prepared returns were divided into nine
income categories (see Appendix B for the sampling stratification).
For the 2009 BTB, respondents were asked to consider the time and out-of-pocket
costs incurred for filing all federal and state business tax returns (income, payroll, excise,
information returns, state and local, etc.). Entities with an in-house tax department were
asked additional questions regarding the budget and staffing for that department. One of
the main concerns in creating the business survey instrument was whether respondents
would be able to separate the compliance costs associated with tax planning and tax
filing, given that many tax service providers bundle these services.
To take into account likely pay rate differences, respondents were asked to prorate
time spent by type of staff doing the work (for example, full-time versus part-time
or executive versus clerical). Respondents were asked to allocate their time burden
across (1) tax compliance activities (such as recordkeeping, tax planning, calculating payroll taxes, and completing and submitting the federal income tax return) and
(2) the type of employee (owners, executives, clerical, and other) performing those
activities.
Cost-related questions included fees paid to external service providers for tax and
tax-related services, the cost of tax-related software, and the amount spent on other
tax-related activities (copies of tax returns, postage, etc.). Respondents were asked to
provide total amounts for each of these items, as well as indicating how much of those
costs were spent specifically for federal income tax compliance.
The 2009 BTB was conducted in five waves from July 27, 2010, to April 25, 2011.
A total of 19,187 surveys were mailed and 5,256 responses were received.
IV. COMPLIANCE COST MODELS
The survey data makes it possible to begin developing a model that can be used for
forecasting and simulation of changes in the underlying tax law, IRS administrative
procedures, and taxpayer behavior.
A. First Step — A Cost-Minimization Model
To guide development of compliance cost models for a “what-if” analysis, a simple
economic model was developed based on the premise that a rational taxpayer will
choose between preparing his return himself or seeking the services of a third party
preparer depending on which choice minimizes tax burden, holding constant all other
influencing factors. This economic model of compliance costs was developed following
the work of Slemrod (2001) and Eichfelder and Schorn (2009).
Compliance cost consists of the individual’s or firm’s compliance burden, which is
a function of resources spent plus the cost of hiring an outside tax specialist. Filing
activities are the first part of the constraint in the minimization mode — the activities

Income Taxes and Compliance Costs: How Are They Related?

841

needed to file a tax return. The amount of activities needed depends on the entity’s
earnings, tax planning, and the need to meet recordkeeping and tax reporting compliance requirements.
Resource production, the output produced by the resources used, is the other part of
the constraint. In this model, a rational taxpayer will choose the allocation of personal
and third party resources to minimize total compliance cost while conducting only those
activities needed for tax compliance. The gross marginal cost of in-house resources
may not be greater than the market price of outsourced tax compliance activities. Key
implications of this modeling framework are as follows:6
1. As personal productivity increases, holding all else constant, the taxpayer uses
more personal resources and fewer third party resources;
2. As the price of third party tax assistance increases, holding all else constant, the
taxpayer uses more personal resources and fewer third party resources;
3. As a taxpayer’s earnings increase, holding all else constant, the taxpayer solely
relies on additional third party resources; and
4. As earnings increase, compliance costs increase.
B. The Econometric Models
The IRS burden model methodology, developed in partnership with the U.S. Department of the Treasury Office of Tax Analysis, establishes econometric relationships
between tax return characteristics from IRS administrative data and the time and outof-pocket costs reported by those taxpayers via an IRS taxpayer burden survey. The
current methodology is based on the activities performed by the taxpayer rather than
the actual forms and schedules used. The methodology also differentiates compliance
cost based on tax characteristics and the amount of reported economic activity. The
results control for the substitution of time and money by monetizing time and reporting
total compliance costs in dollars.
1. Individual Taxpayer Burden Model (ITBM)

Following the methodology in Contos et al. (2009a) and Contos et al. (2009b), which
modeled the compliance burden of small businesses, we employ a log-linear specification in which the logarithm of the burden is linearly related to a set of explanatory
variables, described in further detail in Contos, et al. (2010). The dependent variable is
based on survey responses, and is defined as the logarithm of total pre-filing and filing
compliance costs — that is, the monetized time and money taxpayers spend to comply
with federal tax laws.
6

The modeling framework is adapted from Eichfelder and Schorn (2009), Appendix C.

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Table 1 shows the estimated coefficients used in the ITBM based on updated information from the 2010 ITB survey. Note that the coefficient for the logarithm of modified
positive income (MPI) is positive and less than one, so compliance costs increase with
MPI, but at a decreasing rate.7
The most unique aspect of modeling compliance burden is the need to control for the
type and volume of activities performed by taxpayers to meet their federal tax obligations. Therefore, we developed a proxy for the type of activities performed. Each tax
item from the primary forms and schedules is rated as “Low,” “Medium,” or “High,”
based on the notion that burden increases as a function of both the type of tax-related
activities completed by the taxpayer as well as the volume completed. For example,
if an individual completes an additional tax item one year, holding all else constant,
compliance burden should increase because the taxpayer will have adjusted his recordkeeping, familiarized himself with the relevant taxpayer instructions, or perhaps paid
higher preparation fees.

Table 1
Individual Taxpayer Regression Results
Burden Coefficients
Variable
Intercept
Ln(Modified Positive Income)
Ln(Modified Positive Income) and Paid Prepared Return
Low Complexity
Medium Complexity
High Complexity
Ln(Line Count of Self Prepared Return)
Ln(Line Count of Software Prepared Return)
Ln(Line Count of Paid Prepared Return)
Paid Prepared Return
Software Prepared return

Estimate

T-statistic

–0.769
0.289
0.168
0.006
0.009
0.035
0.399
0.192
0.235
2.708
1.180

–3.700
16.250
10.580
10.140
21.860
10.340
10.010
7.930
8.750
10.900
6.420

Note: Coefficients in bold are statistically significant at the 1 percent level.

7

Modified total positive income (MPI) is defined as the sum of wages and salaries, taxable and nontaxable
interest, dividends, state income tax refunds, alimony received, capital gains, gross retirement income,
gross profit from Schedules C and F, gross profits from active participation in a partnership or S corporation, and certain other miscellaneous income reported on the tax return. Where the only source of income
is from business, MPI reduces to total receipts.

Income Taxes and Compliance Costs: How Are They Related?

843

As a proxy for the volume of activities, we use the money amounts reported by each
taxpayer for that item. This is based on the notion that a larger dollar amount reported
for a tax item is associated with more activity related to that item. The Low, Medium,
and High coefficients (0.006, 0.010, and 0.039, respectively) apply to the logarithms of
the sums of all the values on lines categorized as having the corresponding complexity.
Based on these coefficients, an additional dollar of activity in the high category will
increase burden more than an additional dollar in medium and low.
We include dummy variables to measure the effect of preparation method on compliance burden when self-preparation is the reference category. The remaining preparation
categories represent paid and software preparation. The coefficients for the preparation
dummies are positive because fixed costs are associated with using assisted methods.
As discussed earlier, the trade-off for additional tax preparation costs is a reduction
in the amount of time it would have taken a taxpayer to research and complete the tax
return unassisted. In addition to preparation of their tax returns, taxpayers may also
receive tax-planning advice and can be reasonably assured that they receive all of the
tax benefits to which they are entitled. Taxpayers may also benefit from representation
in the event they are contacted by the IRS about their tax return.
To control for the efficiency gains associated with hiring a paid professional, we
include in the specification an interaction term between the dummy variable for paid
preparation and the logarithm of MPI. This interaction term takes into account the lower
marginal compliance costs associated with using a paid preparer. To control for additional efficiency gains associated with hiring a paid professional or using software, we
include three line count variables that reflect the difference in salience of inapplicable
tax rules conditional on the taxpayer’s preparation method.
2. Business Taxpayer Burden Model (BTBM)

For business entities, we use a model based on Slemrod and Venkatesh (2002) and
Contos et al. (2009b). The dependent variable is the logarithm of total monetized compliance costs. Independent variables include the logarithms of total assets, total receipts,
and the sum of dollars reported for line items requiring either very little or conversely
significant tax-specific recordkeeping, and dummy variables for organizational form,
industry, and use of a paid tax return preparer. Controlling for both assets and total
receipts provides a better fit across a range of types and sizes of businesses. Dummy
variables are used for cases where either assets or receipts are not reported.
Table 2 shows the results of the robust ordinary least squares (OLS) regression of
the complete business econometric model. The estimated coefficient for the natural
logarithm of Total Assets is (as expected) positive and significant at the one percent
level. The same is true for the coefficient on the No Assets variable.
The estimated coefficient for the logarithm of Total Receipts is also positive and
significant at the 1 percent level. The same is true for the No Receipts coefficient. The
coefficient for High Complexity, 0.100, is positive and statistically significant at the

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Table 2
Business Survey Regression Results
Burden Coefficients
Variable
Intercept
Ln(Total Assets)
No Assets Indicator
Ln(Total Receipts)
No Receipts Indicator
Low Complexity
High Complexity
No Complexity
Partnership Indicator
S Corporation Indicator
Self-Prepared Indicator
Positive Tax Liability
Industry Controls

Estimate

T-statistic

4.057
0.188
1.649
0.139
1.564
0.005
0.100
0.787
0.067
–0.013
–0.276
0.08
YES

6.91
17.22
12.24
8.17
7.16
0.64
5.94
3.06
0.96
–0.21
–3.3
0.89

Note: Coefficients in bold are statistically significant at the one percent level.

1 percent level. The fact that this coefficient is positive suggests that increases in the
volume of high complexity activity increases total burden, controlling for other drivers
of burden. The coefficient for Low Complexity (0.005), while insignificant, is expectedly lower than the coefficient for High Complexity. The coefficients for the remaining
variables are also generally in line with our expectations. Using the model, we estimated
that the annual compliance burden for business entities exceeds $100 billion.
V. HOW COMPLIANCE COSTS VARY AMONG TAXPAYERS
As discussed above, survey results are used as inputs for our estimates of individual
taxpayer burden. These data also help us understand how compliance burden varies
among taxpayers. This section shows just a few of the ways compliance burden can
be analyzed.
A. Individual Compliance Costs by Adjusted Gross Income
Table 3 presents individual compliance burden by adjusted gross income (AGI)
expressed in terms of time, out-of-pocket costs, and total monetized costs. To monetize
time for individual taxpayers, we assign an after-tax hourly wage rate based on the tax-

Income Taxes and Compliance Costs: How Are They Related?

845

Table 3
Individual Compliance Burden ($) by AGI Strata

Entire Population
No adjusted gross income
1 to 5,000
5,000 to 10,000
10,000 to 15,000
15,000 to 20,000
20,000 to 25,000
25,000 to 30,000
30,000 to 40,000
40,000 to 50,000
50,000 to 75,000
75,000 to 100,000
100,000 to 200,000
200,000 and more

Population
(Thousands)

Time
(Hours)

Average
Out Pocket
Costs ($)

Average
Monetized
Burden ($)

Burden/
AGI (%)

142,985
2,577
9,961
12,278
12,812
11,742
10,173
8,961
14,620
10,991
18,769
11,828
13,945
4,328

12.54
26.09
7.30
8.95
10.34
11.24
11.30
11.46
11.74
12.69
13.44
14.09
14.51
29.79

198
243
73
97
114
124
128
136
148
164
192
237
328
1,250

373
441
127
164
192
210
222
240
268
315
380
480
670
2,331

6.8
-83.3
2.2
1.5
1.2
1.0
0.9
0.8
0.7
0.6
0.6
0.5
0.5

payer’s marginal tax rate, FICA tax rate (if applicable to income at the marginal rate) and
Medicare tax rate. For self-employed taxpayers, we control for changes in net income
by using a three-year average for year one and the two prior years. All taxpayers are
assigned a monetization rate no less than minimum wage. An upper bound limitation
is applied to take into account the fact that above a certain wage rate taxpayers tend to
use a paid preparer because the value of their time generally exceeds what they would
pay a preparer to complete the return.
These results indicate that compliance costs rise less-than-proportionately with
size, consistent with the results of Slemrod and Blumenthal (1996) and Eichfelder and
Schorn (2009).
Table 4 uses the five ITB survey complexity categories to illustrate how compliance
costs vary based on tax return characteristics. We extend the table to $115,000 AGI for
the sake of illustration. A complete chart shows that average compliance costs tend to
level off as AGI increases.
B. Individual Compliance Costs by Major Segments of the Tax Code
One might think that the myriad of tax deductions and credits available to individuals
would contribute to the bulk of the complexity faced by these taxpayers. However, as
shown in Table 5, the elements of the tax law that deal solely with reporting income

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National Tax Journal

Table 4
Average Compliance Cost by AGI and Complexity Category
Complexity Category
AGI

One
(Low)

Two
Three
(Low-Medium and Medium) (High-Medium and High)

All amounts are in $
0
5,000
10,000
15,000
20,000
25,000
30,000
35,000
40,000
45,000
50,000
55,000
60,000
65,000
70,000
75,000
80,000
85,000
90,000
95,000
100,000
105,000
110,000
115,000
120,000

28
63
86
95
100
106
111
114
119
123
125
129
132
140
137
144
144
140
143
147
151
165
159
170
176

115
146
179
188
190
196
206
222
231
237
249
259
269
281
290
302
316
322
336
337
337
367
371
374
389

452
335
384
414
467
475
480
512
533
528
518
555
574
572
593
625
616
644
677
649
693
680
718
748
714

(before claiming any deductions or credits) comprise more than half of individual taxpayer compliance burden. The proration was derived by stripping away consecutive
categories of burden (other taxes, AMT, credits, deductions, etc.). At each step, tax
liability was recalculated based on the remaining categories to identify the taxpayers
who no longer had a reason to file based on the remaining items. These taxpayers were

Wages
Self-employment Income
Other income
Deductions
Credits
AMT
Other taxes

Category

124,011
132,977
136,974
136,974
139,277
139,277
142,985

Cumulative
Population with
a Reason to File
(Thousands)
9,721
19,667
29,203
42,807
50,230
51,062
53,364

Cumulative
Share of
Burden
($Millions)
9,721
9,946
9,536
13,604
7,423
832
2,302

Share of
Burden
($Millions)
18.2
18.6
17.9
24.5
13.9
1.6
5.3

All
Taxpayers

12.7
0.5
10.3
7.3
5.5
0.4
1.4

W&I
Taxpayers

5.5
18.1
7.5
17.2
8.4
1.2
3.9

SE
Taxpayers

Share of Compliance Burden (%)

Table 5
Allocation of Individual Taxpayer Compliance Costs

Income Taxes and Compliance Costs: How Are They Related?
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removed from the burden estimation calculation. The resulting change in the estimated
burden was assigned to the category that was removed.8
For example, as a first step we removed all of the tax-related reporting items that did
not fit into one of the other categories. After removing these items, about four million
(143 million minus 139 million) taxpayers no longer had a reason to file. When we reestimated burden for the remaining taxpayers, the result was about 4 percent lower than
total estimated burden. Thus, the “Other taxes” category is estimated to contribute 4
percent to overall estimated taxpayer burden for all individual taxpayers. We then broke
out the share of compliance burden between wage and investment (W&I) taxpayers
and self-employed (SE) taxpayers.
We found that over half of the individual income tax compliance costs are associated
with reporting and substantiating income, even for taxpayers with relatively simple
sources of income. Taxpayers with simpler sources of income also tend to have fairly
simple deductions and credits, or none at all. Note that this analysis only considers the
cost to the taxpayer. If we were to consider the costs of issuing information returns
such as Forms W-2 and 1099, the overall share of income tax compliance costs would
be even more heavily weighted towards reporting and substantiating income.
One thing that must be considered is that the measurement methodology discussed
above ignores the impact that complexity has on what taxpayers choose not to do because
it is too burdensome, such as choosing not to keep records necessary to claim a tax
benefit or even not to comply with certain reporting requirements. Also, we recognize
that we may undervalue self-employed taxpayers’ time, given that net self-employment
income may not properly reflect the opportunity cost of starting a new business or the
complexity associated with deductions that offset the business’s income.
C. Business Compliance Costs
For business entities, we break down compliance burden in terms of either total
receipts or asset size. Table 6 shows the estimated total monetized business compliance
burden by revenue strata and business entity type, including costs passed through to the
individual level and using a variable monetization rate based on entity size.
As shown in Table 6, compliance burden varies greatly depending on the type of
entity and the entity’s gross receipts. As with individual returns, compliance costs tend
to increase as income increases, but at a decreasing rate.
D. Compliance Costs versus Compliance Burden
Virtually all estimates of compliance costs constructed by government and academic
economists, including our own, are estimates of the social costs imposed on the economy
by tax compliance. The estimates represent the upper bound on the direct costs imposed

8

Taxpayers are considered to have a reason to file if they have a filing requirement or are eligible for a
refund.

Income Taxes and Compliance Costs: How Are They Related?

849

Table 6
Income Tax Compliance Costs (Tax Year 2009) from BTBM
by Size of Receipts, Using a Variable Monetization Rate
Total Receipts
($Million)

C Corporations S Corporations

Partnerships

All

3,900
9,800
27,600
89,800
504,000

6,700
18,100
43,500
134,600
645,800
13,400

5,300
12,500
34,000
128,200
925,400
$11,600

7.9
16.6
9.6
2.2
0.0*
36.3

14.2
14.9
8.7
4.3
0.4
42.5

25.9
40.3
25.1
10.7
2.1
104.1

Panel A: Average Compliance Costs ($)
0
to
0.10
0.10 to
1
1
to
10
10
to
500
500 and more
All Receipt Sizes

4,700
13,000
35,700
157,800

Panel B: Total Compliance Costs ($Billion)
0
to
0.10
0.10 to
1
1
to
10
10
to
500
500 and more
All Receipt Sizes

3.7
8.8
6.9
4.2
1.7
25.3

*Total compliance cost is less than $50 million.

on the taxpaying entities. Because some tax compliance costs, such as fees for tax
planning and tax preparation, are deductible, the actual taxpayer burden incurred is
reduced.
The impact of tax deductibility varies by the legal form of the taxed entity and can
range from a negligible impact for individual taxpayers to very large for taxable corporations with taxation at the corporate level as well as on distributed dividends at the
individual level. The spread between compliance costs and compliance burden depends
on the value of the tax deduction for the compliance costs. For individuals, nonbusiness
and investment-related out-of-pocket compliance costs (e.g., tax preparation fees, cost
of investment advice) are deductible only if the taxpayer itemizes deductions and then
only to the extent that the total of these costs and certain other miscellaneous deductions exceed 2 percent of AGI. Thus the difference between a taxpayer’s compliance
costs and the associated burden is very modest for nonbusiness compliance costs. For
partnerships and S corporations, compliance costs directly reduce the taxable income
of partners and S corporation shareholders. For C corporations, deductible compliance
costs reduce the amount of income subject to tax, and also reduce the taxable income
on which dividends are paid.

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For example, suppose Corporation A has an average marginal tax rate of 30 percent
at the federal level. For this purpose, ignore the state tax and dividend paid deductions.
Under these assumptions, $1,000 of deductible tax compliance expenses reduces tax
paid at the corporate level by $300. Thus, the corporation’s net compliance burden is
$700. The other $300 in cost has been shifted to other parts of the economy.
VI. CONCLUSION
Our results suggest that over half of individual income tax compliance costs are associated with reporting income. Consistent with the rest of the literature on this topic, we find
marginal costs decrease with the scale of reporting. Additional complexity is mitigated
by the application of technology and specialized expertise providing further decreasing
marginal costs after an initial investment. Deductibility of compliance costs changes the
economic incidence of compliance burden and associated taxpayer incentives.
The tax law already includes many examples of compliance cost mitigation efforts,
such as safe harbors, information reporting, book/tax conformity, and allowing deductions for certain tax preparation expenses. Managing compliance costs benefits from
obtaining information from whoever can provide it at the lowest marginal cost and
evaluating that public cost against the benefit of the information for tax administration.
Understanding the relationship between income taxes and compliance costs can help
focus compliance cost management efforts to areas of greatest impact. Examples of
promising approaches are the minimization or elimination of reporting requirements
when the information obtained is of little use to tax administration, consideration of
whether the benefit of a policy outweighs its reporting costs for various taxpayer segments, and mitigating the main drivers of taxpayer compliance costs.
ACKNOWLEDGEMENTS
We thank Mike Brick, Michelle Chu, Paul Corcoro, Ardeshir Eftekharzadeh, Kerry
Levin, Jocelyn Newsome, Jennifer O’Brien, and Ahmad Qadri for helpful assistance as
well as Janice Hedemann, Janet Holtzblatt, Laura Kalambokidis, Emily Lin, and Janet
McCubbin for valuable comments.
DISCLAIMERS
The views represented are those of the authors and do not necessarily represent the
views of the Internal Revenue Service or the U.S. Department of the Treasury.
REFERENCES
Contos, George, Ardeshir Eftekharzadeh, Brian Erard, John Guyton, and Scott Stilmar, 2009a.
“Econometric Simulation of the Income Tax Compliance Process for Small Business.” In Proceedings of the 2009 Winter Simulation Conference, 2762–2765. Winter Simulation Conference,
http://informs-sim.org/wsc09papers/prog09soc.html.

Income Taxes and Compliance Costs: How Are They Related?

851

Contos, George, John Guyton, Patrick Langetieg, and Susan Nelson, 2009b. “Taxpayer Compliance Costs For Small Businesses: Evidence From Corporations, Partnerships, and Sole Proprietorships.” In Proceedings of the One Hundred Second Annual Conference on Taxation, 50–59.
National Tax Association, Washington, DC.
Contos, George, John Guyton, Patrick Langetieg, Allen H. Lerman, and Susan Nelson, 2012.
“Taxpayer Compliance Costs for Corporations and Partnerships: A New Look.” In IRS Research
Bulletin: Proceedings of the 2012 IRS Research Conference, 4–18. Internal Revenue Service,
Washington, DC.
Contos, George, John Guyton, Patrick Langetieg, and Melissa Vigil, 2010. “Individual Taxpayer Compliance Burden: The Role of Assisted Methods in Taxpayer Response to Increasing
Complexity.” In Proceedings of the 2010 IRS Research Conference, 191–220. Internal Revenue
Service, Washington, DC.
Eichfelder, Sebastian and Michael Schorn, 2009. “Tax Compliance Costs: A Business Administration Perspective.” Working Paper No. 2009/3. Free University Berlin, School of Business
and Economics, Berlin, Germany.
National Taxpayer Advocate, 2012. “National Taxpayer Advocate’s Fiscal Year 2012 Annual
Report to Congress.” Internal Revenue Service, Washington, DC.
Slemrod, Joel (1996). “Which is the simplest tax system of them all?” in: Henry Aaron and
William Gale, eds., Economic Effects of Fundamental Tax Reform (The Brookings Institution,
Washington, D.C.), 355–391.
Slemrod, Joel, 2001. “A General Model Of The Behavioral Response To Taxation.” International
Tax and Public Finance 8 (2), 119–128.
Slemrod, Joel and Marsha Blumenthal, 1996. “The Income Tax Compliance Cost of Big Business.” Public Finance Quarterly 24 (4), 411–438.
Slemrod, Joel, and Varsha Venkatesh, 2002. “The Income Tax Compliance Cost of Large and
Mid-Size Businesses.” Ross School of Business Paper No. 914. University of Michigan, Ann
Arbor, MI.

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APPENDIX A: DEFINITION OF 2010 ITB COMPLEXITY STRATA

Table A1
Strata

Definition

Low

Wage income
Interest income
Unemployment income
Withholding
Earning income tax credit (with no qualifying children) or advanced EIC
Does not meet any of the conditions for higher levels of differential burden

Low-Medium

Capital gain income (includes capital gains distributions and undistributed
capital gains)
Dividend income
Earned income tax credit (with qualifying children)
Estimated tax payments
Retirement income (includes SS benefits, IRA distributions, or pensions
and annuities)
Any non-refundable credit (includes child and dependent care expenses,
education credits, child tax credit, elderly or disabled credit)
Household employees
Nonbusiness adjustments
Does not meet any of the conditions for higher levels of differential burden

Medium

Itemized deductions (includes mortgage interest, interest paid to financial
institutions, charitable contributions, and medical expenses)
Foreign income, expense, tax, credit, or payment
Moving expenses
Simple Schedule C or C-EZ
General business credit
Does not meet any of the conditions for higher levels of differential burden

Medium-High

Farm income as reported on Schedule F
Owns rental property as reported on Schedule E, including farm rental and
low income housing
Estate or trust income as reported on Schedule E
Employee business expense deductions
Files AMT without AMT preference items
Prior year alternative minimum tax credit
Investment interest expense deduction
Net loss as reported on Schedule C
Depreciation or amortization as reported on Schedule C
Expenses for business use of home as reported on Schedule C
Does not meet any of the conditions for higher levels of differential burden

High

Cost of goods sold as reported on Schedule C
Partnership or S-Corp income as reported on Schedule E
Files AMT with AMT preference items

Income Taxes and Compliance Costs: How Are They Related?

APPENDIX B: 2010 BTB SAMPLING STRATA

Table B1
Preparation Method Strata
1. Self-Prepared
2. Paid Prepared (defined as presence of a paid preparer)

Total Revenue Strata
Self-Prepared
1. Less than $5,000
2. $5,001–$100,000
3. $100,001–$1,000,000
4. $1,000,001 or more
Paid Prepared
1. Equal to zero
2. $1–$5,000
3. $5,001–50,000
4. $50,001–$100,000
5. $100,001–$500,000
6. $500,001–$1,000,000
7. $1,000,001–$5,000,000
8. $5,000,001–$10,000,000
9. $10,000,001 or more

853