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GAO-04-79R 1 (2003-11-06)

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       Accountability * Integrity * Reliability
United States General Accounting Office
Washington, DC 20548



         November 6, 2003


         The Honorable Mark W. Everson
         Commissioner of Internal Revenue

         Subject:    IRS's Use of Information on Taxpayers Claiming Many Allowances or
                     Exemption From Federal Income Tax Withholding

         Dear Mr. Everson:

         In September 2003, we responded to a request from Representative Elton Gallegly to
         provide information on the number of taxpayers who claimed more than 10
         withholding allowances and taxpayers who claimed exemption from federal income
         tax withholding. The Internal Revenue Service (IRS) calls such claims questionable
         Form W-4s. However, in the course of performing our work, we became concerned
         about the reliability of the information that IRS maintains on these taxpayers and
         decided that we could not use it to answer Representative Gallegly's questions. For
         background, see our letter to Representative Gallegly in enclosure 1.

         The objectives of this letter are to summarize our findings about the reliability of the
         information IRS maintains on taxpayers who claimed more than 10 withholding
         allowances or exemption from federal tax withholding and to bring to your attention
         some resulting questions about the value of IRS continuing to collect the information.

         Results

         We have two concerns about the information that IRS maintains on taxpayers who
         claimed more than 10 withholding allowances or exemption from federal tax
         withholding that precluded us from using it to respond to Representative Gallegly's
         questions. First, we are concerned about the completeness of the information
         because a significant number of employers may not send IRS the required forms.
         According to IRS's information, about 75 percent of the large employers with 1,000 or
         more employees in its Large and Medium-Size Business (LMSB) and Small
         Business/Self-Employed (SB/SE) divisions that filed employment tax returns in tax
         year 2001 did not send IRS any forms. Although the number of questionable Form
         W-4s IRS might receive from individual employers can vary, it seems unlikely that 75
         percent of employers with 1,000 or more employees could have no employees who
         submitted questionable Form W-4s. Second, some of the information may not be
         current-it may not reflect the current withholding status of some taxpayers. If an
         employee who previously claimed more than 10 allowances or claimed exemption


GAO-04-79R IRS's Questionable Form W-4 Program

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