IRS Collectibility Curve
Tom Beers, Carol Hatch, Joe Saldana, and Je Wilson,
Taxpayer Advocate Service Research, Internal Revenue Service
Introduction
When taxpayers incur delinquent tax liabilities, the Internal Revenue Service (IRS) sends them a series of notices dur-
ing a -month period during which the taxpayers are in “notice status.” If the taxpayer does not resolve his or her li-
ability during notice status, the account enters into taxpayer delinquent account (TDA) status. e IRS then determines
whether the case will be referred to the Automated Collection System (ACS), assigned directly to the Collection Field
function (CFf) for in-person contact by a revenue ocer, assigned to the Collection Queue (“Queue”) to await assign-
ment to a revenue ocer, or shelved.
1
e ACS is a computerized inventory system and telephone call center. Aer a case arrives in ACS, the IRS checks
for levy sources, telephone numbers, and other characteristics. ese actions result in additional computer-generated
notices to taxpayers. Customer Service Representatives (referred to as “Collection Representatives”
) work ACS cases
and primarily respond to phone calls from taxpayers who call in response to IRS enforcement actions (e.g., levies or
liens) rather than proactively contacting taxpayers.
e Queue is an electronic holding bin that holds TDA accounts awaiting assignment to eld revenue ocers
based on inventory levels.
Cases assigned to the Queue are prioritized using a risk scoring algorithm. Shelved cases
are not actively worked by the IRS while in shelved status, but continue to accumulate penalties and interest. is study
does not specically explore collections on shelved cases.
TAS was interested in examining what happens over the life of a tax debt: do people pay more of the tax debt if
collections are made earlier in the debt cycle (closer to when the debt actually occurs)? Are there patterns that indicate
the likelihood of collecting a debt over time? To this end, TAS Research examined the Individual Master File (IMF)
Accounts Receivable Dollar Inventory (ARDI) to determine how dollars collected uctuate as time elapses.
We looked at delinquencies that originated in each of years ( through ) and analyzed those delinquen-
cies over two time periods: the next years and the next years.
For purposes of brevity, the tables in the body of this
paper include only newly assigned TDAs in , , , , and ; however the Appendix contains data on
TDAs newly assigned from through .
Budgetary constraints will make the ecient collection of delinquencies paramount. e IRS should use data on
the practical delinquency collection “window” to form the basis for its Collection policies. Good information on the
time available to collect various delinquencies eectively will assist the IRS in determining what liabilities should be
collected rst and if it makes sense to defer the collection of smaller more current liabilities in favor of older, larger li-
abilities. Furthermore, this research may provide signicant insights into which delinquencies the IRS should place in
the Collection TDA queue and which it should shelve.
Background
In past Annual Reports to Congress, the National Taxpayer Advocate noted that many of the TDAs in the IRS Automated
Collection Branch and the CFf are delinquencies that have existed for several years. e following statistics highlight
the age of the IRS TDA inventory:
6, 7
1
Shelving refers to the IRS reporting a liability as currently not collectible because of its small balance due.
2
IRM 21.1.1.6.
3
Work also goes into the Queue from ACS if it cannot be resolved while in ACS status.
4
We chose the 10-year period for analysis because the IRS’s authority to collect delinquent taxes, i.e., the collection statute, expires 10 years aer the date of assessment.
5
e IRS places TDAs in the collection queue until a revenue ocer is available to work the case.
6
A TDA represents only one module, generally a tax return for a single tax year. A taxpayer may have multiple TDA delinquencies.
7
IRS Collection Activity Report 5000-2 (Oct. 3, 2014).
Beers, Hatch, Saldana, and Wilson
• Overall, 53 percent of the IRS IMF TDA inventory has been in the function assigned the delinquency for at least
10 months (the delinquency may have been in TDA status much longer);
• Over 70 percent of the IMF TDAs in IRS inventory at the end of 2014 are Tax Year 2010 and prior liabilities; and
• Over 20 percent of the IMF TDAs have less than 4 years remaining on the collection statute, meaning that the
delinquency has existed for over 6 years.
Objectives
We identied nine objectives to explore the relationship between the age of a TDA and the dollars that the IRS collects
on these liabilities. ese objectives explore the dollars collected as TDAs age, and dierentiate between dollars col-
lected from subsequent payments and dollars collected by oset.
,
We also explore subsequent payments and osets by
various categories of the balance due amount, the type of assessment, and the accumulation of penalties and interest.
Specically, for IMF liabilities reaching TDA status, we:
• Determine amounts collected from subsequent payments on delinquencies for the 3 years aer the liability
reaches TDA status;
• Quantify the dollars from subsequent payments collected during the entire 10-year collection statute;
• Delineate the dollars collected from osets of other overpayments and compare them to collections from other
subsequent payments;
• Determine how the collection of liabilities varies by the amount of the delinquency;
• Determine if the rate of collection varies between self-reported liabilities and additional assessments;
• Quantify how penalty and interest cause the liability from a tax assessment to increase the total balance due;
• Determine the percent of liabilities abated by the IRS and if the percentage abated varies by the source of
assessment;
• Examine the percent of cases resolved during the 10-year collection statute; and
• Determine if the percent of TDA dollars collected varies by Collection channel.
Methodology
TAS Research examined the IMF ARDI to determine how dollars collected uctuate as time elapses. We looked at de-
linquencies that entered TDA status from through . We analyzed liabilities entering TDA status in , ,
and for years.
10
We analyzed the later years through . We focused initially on payments received during
the rst years aer the accounts entered TDA status. To examine payments over the -year collection statute and to
better dierentiate between subsequent payments and osets from other taxpayer overpayments, we used transaction
code data from the IMF. is allowed us to distinguish between payments and osets, as well as to quantify abate-
ments.
11
Transaction codes were also used to classify assessed interest and penalties.
12
We classied a liability by the
rst calendar year when it reached TDA status. If a delinquent module le and returned to TDA status, we continued
to classify it by the rst year the IRS assigned the liability to TDA status.
13
We used the major source of assessment (from the ARDI le) to classify the source of assessment. Sometimes, a li-
ability is comprised of more than one type of assessment. For example, a liability might be comprised of a self-reported
assessment and an audit assessment. In this case, the type of assessment is the one most signicantly contributing to
8
Subsequent payments include voluntary payments from taxpayers, such as those from installment agreements, and involuntary payments such as from an IRS levy.
9
Dollars collected from refunds or overpayments due to the taxpayer.
10
TDAs originating in 2005 will have been in notice status for several prior months. erefore, the 10-year statute will have expired or be about to expire in 2014.
11
Payments include one of the following transaction codes: 610, 611, 612, 640, 641, 642, 660, 661, 662, 666, 667, 670, 671, 672, 673, 680, 681, 682, 683, 690, 691, 692, 693, 694,
695, 760, 762, and 763. Osets include one of the following transaction codes: 700, 701, 702, 703, 706, 710, 712, 713, 716, 720, 721, 722, 723, 730, 736, 740, and 742. Abatements
include one of the following transaction codes: 161, 167, 171, 177, 181, 187, 191, 197, 235, 239, 241, 247, 271, 277, 281, 287, 291, 295, 299, 301, 305, 309, 321, 337, 341, 342, 351,
361, 538, and 549.
12
Interest includes the following transaction codes: 190 and 196. Penalties include the following transaction codes: 160, 166, 170, 176, 270, 276, 280, 286, 320, and 350.
13
A delinquent account can leave TDA status and enter into another status. For example, if the taxpayer enters into an installment agreement (IA) to repay the delinquency, the
account leaves TDA status and enters into IA status. If the taxpayer subsequently defaults on the IA, the account will reenter TDA status.
IRS Collectibility Curve
the balance owed. We determined whether the IRS assigned a TDA liability to ACS, collection queue, or CFf by the
Taxpayer Service Returns Processing Category (TRCAT) code, which diers depending on where a liability is located
in the collection stream.
Limitations
When we discuss changes in the total module balance of TDAs, we have included both assessed and accrued penalties
and interest. However, in the specic objective regarding penalties and interest balance, we have tracked only assessed
penalties and interest but have not quantied accrued penalties and interest. Additionally, interest assessed amounts do
not contain restricted interest assessments.
14
Although it is a relatively small portion of abatements, dollars abated as a
result of accepted oers in compromise are included in total abatements.
15
Findings
In this section, we present the ndings for each of the objectives. In addition to providing the data pertinent to each
objective, we also oer some insights on whether the results are changing over time and why the underlying trends are
present.
Determine amounts collected from subsequent payments on delinquencies for the 3 years aer the liability reaches TDA
status.
16
For TDAs originating aer , our analysis showed that: (a) dollars collected decrease by more than percent from
the rst year to the second year; and (b) in the third year, collections decrease by about one-third from the amount col-
lected in the second year.
17
In other words, collections are over twice as much during the rst year as in the following
year and over three times the collection in the third year. For TDAs originating in , collections declined by about
percent during the second year aer the cases entered TDA status. For , the decrease in total dollars collected
in the third year was only about percent. Nevertheless, overall collections for cases entering TDA status aer
decreased by about two-thirds from the rst year to the third year aer entering TDA status.
Table depicts these ndings by the years elapsed since the initial liability reached TDA status:
TABLE 1. Subsequent Payments (in $ Millions) Decrease as Time Elapses, Selected Years
Assigned TDA
2003 2005 2007 2009 2011
Years Elapsed
Subsequent Payments
% Decrease in Collections
from Prior Year
Subsequent Payments
% Decrease in Collections
from Prior Year
Subsequent Payments
% Decrease in Collections
from Prior Year
Subsequent Payments
% Decrease in Collections
from Prior Year
Subsequent Payments
% Decrease in Collections
from Prior Year
1 $1,786.4 $2,990.8 $3,664.8 $3,631.9 $3,800.1
2 $1,166.8 -35% $1,344.1 -55% $1,330.4 -64% $1,675.5 -54% $1,748.1 -54%
3 $848.5 -27% $ 832.6 -38% $907.0 -32% $1,216.8 -27% $1,177.6 -33%
Despite accumulation of penalty and interest, as the IRS collects additional dollars, the balance due declines over
time.
Table shows the overall decline in total module balance over the rst years aer the liability reached TDA
status:
14
Restricted interest is assessed by transaction code 340 (and abated by transaction code 341). Restricted interest arises when any portion of the interest on an overpayment or
underpayment is calculated from a date other than the one that applies to the return as led. is happens most oen when there is a carryback of a loss or credit.
15
e Fiscal Year (FY) 2014 liabilities compromised were 1.2 percent of the amount of TDAs at the beginning of FY 2014.
16
Subsequent payments include voluntary payments from taxpayers such as those from IAs and involuntary payments such as from an IRS levy.
17
In 2003, collections of new TDAs decreased by only about 35 percent from the rst to the second year, even though the decrease from the second to the third year was similar
to later years. See the Appendix for complete details on all years studied.
18
is is true only if the dollars collected exceed penalty and interest accruals. In an earlier study examining only currently not collectible (CNC) cases, the module balance
actually increased as time elapsed.
Beers, Hatch, Saldana, and Wilson
TABLE 2. Rate of Module Balance Decline Slows, Selected Years Assigned TDA
2003 2005 2007 2009 2011
Years Elapsed
Total Module Balance
($M)
% Decline in Module
Balance
Total Module Balance
($M)
% Decline in Module
Balance
Total Module Balance
($M)
% Decline in Module
Balance
Total Module Balance
($M)
% Decline in Module
Balance
Total Module Balance
($M)
% Decline in Module
Balance
0 $15,326.2 $25,996.1 $40,678.5 $41,987.7 $42,926.2
1 $12,321.3 -20% $20,872.6 -20% $32,783.3 -19% $35,332.5 -16% $34,795.8 -19%
2 $10,370.3 -16% $17,657.4 -15% $28,948.3 -12% $31,581.2 -11% $29,792.6 -14%
3 $8,841.3 -15% $15,759.1 -11% $26,531.7 -8% $28,767.3 -9% $27,132.4 -9%
Comparing the two previous tables, one notices that the module balance decreases more rapidly than the dollars
collected would indicate. is occurs because of the complete or partial abatement of some liabilities, particularly dur-
ing the rst years of a delinquency. We will explore abatements in greater detail in a subsequent section.
On a percentage basis, the dollars collected drop signicantly from the rst year to the second year, but the de-
crease slows in the third year. We will explore this issue further in the next study objective when we look at the entire
-year statutory period to collect delinquent tax liabilities.
Even though the original module balance is declining, the percent collected of the balance is also declining as il-
lustrated in Figure :
FIGURE 1. Decline in Dollars Collected as a Percent of Module Balance
0%
2%
4%
6%
8%
10%
12%
14%
123
YearsElapsed
2003
2005
2007
2009
2011
An analysis of the data shows that dollars collected decrease as a liability ages. Dollars collected as a percentage
of the prior-year dollars collected also decline signicantly. Finally, the percent of the original TDA liability, including
penalties and interest, being collected decreases signicantly from the rst year to the second year and then continues
to decline, but at a slower rate. Accordingly, the rate at which the total amount of the delinquency decreases slows as
time progresses.
IRS Collectibility Curve
Quantify the dollars from subsequent payments collected during the entire 10-year collection statute.
In the rst objective, we looked at the rst years of collections aer a liability reached TDA status. We looked at a
period of years because private collection agencies believe that nearly all monies on delinquent debts are collected
within the rst years aer the debt becomes due. Next, we will examine what happens over the entire statutory -year
collection period.
Table depicts the subsequent payments by years elapsed since TDA issuance and the percent of the total dollars
collected in each year:
TABLE 3. Subsequent Payments
as a Percent of Total Subsequent Payments Collected Per Year,
Selected Years Assigned TDA
19
2003 2005 2007 2009 2011
Years Elapsed
Amount
($ Millions)
% of Total
Amount
($ Millions)
% of Total
Amount
($ Millions)
% of Total
Amount
($ Millions)
% of Total
Amount
($ Millions)
% of Total
1 31% $2,990.8 41% $3,664.8 43% $3,631.9 42% $3,800.1 51%
2 20% $1,344.1 18% $1,330.4 16% $1,675.5 19% $1,748.1 24%
3 $848.5 15% $832.6 11% $907.0 11% $1,216.8 14% $1,177.6 16%
4 $615.1 11% $535.8 7% $720.3 9% $944.8 11% $688.5 9%
5 $402.9 7% $394.7 5% $600.3 7% $746.6 9% $20.8 0%
6 $254.2 4% $341.3 5% $517.4 6% $379.5 4%
7 $196.6 3% $289.5 4% $417.4 5%
8 $166.0 3% $252.3 3% $272.5 3%
9 $141.4 2% $209.5 3% $7.8 0%
10 $123.3 2% $123.6 2%
Total 100% $7,314.3 100% $8,437.9 100% $8,595.2 100% $7,435.1 100%
Figure illustrates this same information:
FIGURE 2. Percent Collected in up to 10 Years, by Years Elapsed, Five Selected Years
0%
10%
20%
30%
40%
50%
60%
12345678910
YearsElaspsed
2003
2005
2007
2009
2011
19
Subsequent payments include voluntary payments from taxpayers such as those from installment agreements and involuntary payments such as from an IRS levy.
Years Elapsed
Beers, Hatch, Saldana, and Wilson
Table clearly shows a decline in the dollars collected as time elapses throughout the collection statute period.
Dollars collected level o at about percent in the last year of the collection statute. As we saw in the rst objective,
the total balance due also declines, although much more slowly in the latter years. is trend is also illustrated in
Table .
TABLE 4. Decline in Total Balance Owed Within Ten Years After TDA Origination,
Selected Years
Assigned TDA
20
2003 2005 2007 2009 2011
Years Elapsed
Total Module Balance
($M)
% Decline in Module
Balance
Total Module Balance
($M)
% Decline in Module
Balance
Total Module Balance
($M)
% Decline in Module
Balance
Total Module Balance
($M)
% Decline in Module
Balance
Total Module Balance
($M)
% Decline in Module
Balance
0 $15,326.2 $25,996.1 $40,678.5 $41,987.7 $42,926.2
1 $12,202.9 20% $20,955.2 19% $32,849.0 19% $34,910.1 17% $34,032.3 21%
2 $10,705.9 12% $18,585.0 11% $29,935.1 9% $31,718.6 9% $29,319.0 14%
3 $9,603.3 10% $17,390.0 6% $28,301.1 5% $29,367.1 7% $27,055.1 8%
4 $8,947.3 7% $16,596.2 5% $26,943.5 5% $27,478.0 6% $26,304.4 3%
5 $8,477.7 5% $15,982.9 4% $25,668.2 5% $26,092.4 5%
6 $8,148.7 4% $15,505.7 3% $24,806.1 3% $25,649.1 2%
7 $7,835.7 4% $15,067.6 3% $24,032.8 3%
8 $7,522.2 4% $14,613.4 3% $23,740.4 1%
9 $7,139.4 5% $14,138.7 3%
We should note that the total module balance continues to decline because some accounts are paid in full as time
progresses. However, for those accounts that are not resolved, their penalties and interest continue to rise. A larger de-
crease in year occurs because the collection statute has ended for a majority of the liabilities, and the IRS then clears
the previous balance due.
As dollars are collected, the balance due declines over time. Abatements also decrease the liabilities. However,
penalties and interest increase the total amount due. We examined the amount of dollars collected by subsequent pay-
ments as a percent of the module balance at the beginning of each one-year period. Even though the total balance due
generally decreases as taxpayers make subsequent payments and osets and the IRS abates some portion of the assess-
ment, the percent decrease also shows a similar decline in each year during the study period, as illustrated in Table .
TABLE 5. Year-to-Year Percent Decline in Total Balance Due, Selected Years Assigned TDA
Years Elapsed 2003 2005 2007 2009 2011
1 12% 12% 9% 9% 9%
2 10% 6% 4% 5% 5%
3 8% 4% 3% 4% 4%
4 6% 3% 3% 3% 3%
5 5% 2% 2% 3%
6 3% 2% 2% 1%
7 2% 2% 2%
8 2% 2% 1%
9 2% 1%
10 2% 1%
20
e ending balance aer 10 years is not shown. Since the 10-year collection statute generally expires in the 10th year aer the IRS assigns a case to TDA status, the module
balance becomes signicantly reduced by the abatements of liabilities that the IRS is no longer permitted to collect.
IRS Collectibility Curve
As a percentage of the balance due, dollars collected generally drop most precipitously from the rst to the second
year. As the table indicates, the ratio of dollars collected to balances due drops as elapsed time increases.
Determine the dollars collected from osets of other overpayments and compare to collections from other subsequent
payments.
Analysis of the collection activity reports for a number of years shows that a signicant percentage of the total dollars
collected come from refund osets, particularly in ACS. erefore, we distinguished between dollars collected through
subsequent payments
21
and dollars collected through osets from overpayments on other tax modules. Table com-
pares the amount and percent of the initial balance due collected by subsequent payments to collections by osets from
overpayments (refunds) on other tax accounts (generally other tax years).
TABLE 6. Dollars Collected and Offset, Selected Years ($ in Millions)
Year Assigned
TDA
Balance Due
Subsequent
Payments
% Collected Amount Offset % Offset
Total %
Collected
2003 $15,326.2 $5,701.2 37.2% $ 2,150.7 14.0% 51.2%
2005 $25,996.1 $7,314.3 28.1% $ 3,086.5 11.9% 40.0%
2007 $40,678.5 $8,437.9 20.7% $ 4,493.5 11.0% 31.8%
2009 $41,987.7 $8,595.2 20.5% $ 4,173.6 9.9% 30.4%
2011 $42,926.2 $7,435.1 17.3% $ 3,583.2 8.3% 25.7%
For delinquencies reaching TDA status in , the amount collected from subsequent payments is nearly three
times the amount oset. However, for delinquencies reaching TDA status in later years, subsequent payments are
only about twice the amount oset. On a percentage basis to the amount initially owed, subsequent payments have
decreased signicantly from TDAs rst assigned in to TDAs rst assigned in ; however, osets have remained
relatively stable, decreasing by only a few percent. While it is true that delinquencies reaching TDA status since
still have some years remaining on the collection statute, the dollars collected increased by less than percent during
the last years of the -year collection statute for TDAs issued in and . erefore, it is unlikely that dollars
collected from TDAs issued in later years will increase suciently to realize the same proportion of dollars collected
to dollars oset as in earlier years. Since osets are relatively at over the period examined, we generally see the same
trends in total dollars collected, as we saw when examining only subsequent payments.
Determine how the collection of liabilities varies by the amount of the delinquency.
In addition to comparing the dollars collected by subsequent payments and the osets of overpayments, we also com-
pare the dollars collected by subsequent payments and osets in six ranges of the balance due. As one might expect, the
IRS collects a greater percentage of the liability when it is not more than ,.
As illustrated in Table , an analysis of the TDA modules clearly shows that the majority of delinquency amounts
do not exceed ,. However, higher dollar ranges contain the highest percentage of the delinquent dollars, even
though these categories contain only a small percent of the delinquent modules. For example, in , about three-
quarters of the TDA modules were under ,, while over percent of the delinquent dollars were in the highest
three balance due ranges, i.e., the categories greater than ,. In fact, over half of the overall delinquent dollars
were on modules with more than , due. Interestingly, however, from to , the percent of delinquent
TDA modules under , fell from over percent to under percent while the percent of dollars in the highest
three dollar ranges increased from under percent to over percent. is trend indicates that more taxpayers owe
liabilities over ,.
Ination undoubtedly accounts for part of this increase, rising by about percent during this
period, but the combined initial TDA balance for modules with balances greater than , is nearly three times as
high in as in .
is increase in balance due is a disturbing trend for the IRS.
21
Subsequent payments include voluntary payments from taxpayers such as those from installment agreements and involuntary payments such as from an IRS levy.
22
For liabilities entering TDA status in 2009, only about 60 percent of the delinquent modules had liabilities of $5,000 or less. is situation may be attributable to the depressed
economic conditions in 2008.
23
Bureau of Labor Statistics Consumer Price Index ination calculator available at: http://www.bls.gov/data/ination_calculator.htm.
Beers, Hatch, Saldana, and Wilson
TABLE 7. Modules, Balance Due, and Dollars Collected by Initial Module Liability Dollar Range
Year Description
$1
to
$1,000
$1,001
to
$2,000
$2,001
to
$5,000
$5,001
to
$10,000
$10,001
to
$25,000
Greater
Than
$25,000
2003
Module Count 451,712 505,146 565,164 250,331 160,431 92,971
Percent of Modules in Range 22% 25% 28% 12% 8% 5%
Aggregate Balance Due $240.8 $740.6 $1,793.1 $1,745.4 $2,446.9 $8,359.3
Percent of Total Balance in Range 2% 5% 12% 11% 16% 55%
Percent Collected by Subsequent Payment 66% 49% 49% 48% 43% 29%
Percent Collected by Offset 50% 44% 35% 22% 13% 5%
2005
Module Count 467,988 561,662 762,610 388,628 254,399 172,255
Percent of Modules in Range 18% 22% 29% 15% 10% 7%
Aggregate Balance Due $250.8 $832.9 $2,462.5 $2,713.9 $3,886.6 $15,849.4
Percent of Total Balance in Range 1% 3% 9% 10% 15% 61%
Percent Collected by Subsequent Payment 79% 54% 50% 44% 37% 18%
Percent Collected by Offset 55% 50% 38% 23% 13% 3%
2007
Module Count 781,534 666,064 1,006,717 616,892 408,744 260,839
Percent of Modules in Range 21% 18% 27% 16% 11% 7%
Aggregate Balance Due $449.3 $978.5 $3,313.1 $4,309.5 $6,214.7 $25,413.3
Percent of Total Balance in Range 1% 2% 8% 11% 15% 62%
Percent Collected by Subsequent Payment 60% 45% 40% 33% 27% 13%
Percent Collected by Offset 61% 51% 37% 23% 12% 3%
2009
Module Count 520,936 596,584 1,038,155 697,679 479,893 292,604
Percent of Modules in Range 14% 16% 29% 19% 13% 8%
Aggregate Balance Due $290.8 $907.6 $3,388.5 $4,874.9 $7,346.0 $25,179.9
Percent of Total Balance in Range 1% 2% 8% 12% 17% 60%
Percent Collected by Subsequent Payment 58% 40% 35% 27% 23% 15%
Percent Collected by Offset 46% 40% 31% 19% 10% 4%
2011
Module Count 825,154 754,679 1,136,688 639,600 422,102 246,137
Percent of Modules in Range 20.5% 18.8% 28.2% 16% 10% 6%
Aggregate Balance Due $480.4 $1,117.9 $3,718.7 $4,484.3 $6,436.7 $26,688.3
Percent of Total Balance in Range 1% 3% 9% 10% 15% 62%
Percent Collected by Subsequent Payment 37% 27% 22% 18% 17% 11%
Percent Collected by Offset 47% 39% 27% 16% 9% 2%
We also see in Table that the percent of dollars oset is highest in the lowest dollar categories of TDA dollars due,
declining as the balance due increases. As the table indicates, about half of delinquency amounts up to , are col-
lected by refund osets. Since a majority of the TDAs in ACS have lower balances due, it is not surprising that almost
half of the ACS total dollars collected are from osets.
e dollars collected from osets also decline as the TDA bal-
ance due increases.
We see from Table that more than percent of the initial balance is sometimes paid. is occurs because penal-
ties and interest have continued to accrue so the nal balance paid by the taxpayer is signicantly higher than the initial
balance due.
Determine if the rate of collection varies between self-reported liabilities and additional assessments.
We explored whether the amount collected by the IRS depends on the source of the underlying assessment. Specically,
we examined whether the IRS collects a greater percentage of self-reported liabilities than liabilities initiated or in-
creased by the IRS (e.g., additional assessments from audits, third-party information matching (AUR), or Automated
24
Collection Activity Report 5000-2 (Oct. 2014). For individual liabilities, osets actually exceeded dollars collected through collection activities and voluntary subsequent
payments.
IRS Collectibility Curve
Substitute for Returns). As expected, the IRS is more successful at collecting self-reported liabilities than additional
assessments. Table depicts the dierence between percentages of the initial liability collected by subsequent payment,
based on the source of the liability.
TABLE 8. Percent Collected by Subsequent Payment Based on Source of Assessment
Year
Self-Reported
Assessments
Substitute for
Return
Audit
Assessments
AUR
Assessments
Trust Fund Re-
covery Penalties
2003 56% 14% 23% 33% 16%
2005 60% 13% 28% 31% 17%
2007 51% 10% 24% 25% 12%
2009 45% 9% 21% 24% 9%
2011 40% 7% 15% 21% 8%
Clearly, the IRS is most likely to collect self-reported liabilities, which it does at a rate at least twice as great as it
collects audit assessments.
In general, the IRS collects a slightly higher percentage of AUR assessments than audit
assessments. e IRS also collects only a small percentage of substitute for returns and trust fund recovery penalty
assessments.
Figure illustrates the dierence in the percent of the initial liability collected by subsequent payment for various
assessment types.
FIGURE 3. Percent of Initial TDA Liability Collected by Subsequent Payment, Based on
Assessment Type
0%
10%
20%
30%
40%
50%
60%
70%
2003 2005 2007 2009 2011
InitialTD AYear
Self‐ReportedAssessments SubstituteforReturn AuditAssessments
AURAssessents TrustFundRecoveryPenalties
Interestingly, the dollars collected on all of these types except audits have declined signicantly since . is
disturbing trend merits additional investigation.
25
It seems reasonable that taxpayers who assess themselves a balance due are more willing to pay than those who are audited. is may also reect the fact that returns expected
to generate larger audit assessments tend to be selected for audit and, as our analysis shows, a smaller percent of large liabilities—i.e., liabilities exceeding $5,000—are ultimately
collected.
26
Since the collection statute has not expired for cases reaching TDA status in the latter years shown in the chart, more monies will be collected; however, as we have shown, we
do not expect the IRS to collect many more dollars on these liabilities in the last half of the collection statutory period.
Beers, Hatch, Saldana, and Wilson
We also broke out osets from the total dollars collected and explored the dollars collected due to osets. e IRS
collects a higher percentage of AUR assessments through osets than any other type of assessment, even self-reported
assessments. Table displays the percent of the initial TDA balance oset by source of assessment.
TABLE 9. Percent Collected by Offsets Based on Source of Assessment
Year
Self-Reported
Assessments
Substitute for
Return
Audit
Assessments
AUR
Assessments
Trust Fund
Recovery
Penalties
2003 18% 4% 12% 34% 6%
2005 20% 5% 20% 32% 6%
2007 20% 5% 25% 36% 6%
2009 15% 4% 20% 28% 6%
2011 10% 2% 12% 25% 4%
Also, the dierence in oset dollars collected between audit and self-reported assessments is not as great as the
dierence of oset dollars collected between audit and AUR additional assessments. In fact, AUR assessments actually
resulted in the highest percent of the liabilities paid by oset—almost twice that of self-reported liabilities.
AUR liabilities also account for three times the percent of dollars oset to audit liabilities in . While the gap
in dollars oset between AUR and audit liabilities has narrowed by , it is still signicant. Perhaps the reason AUR
assessments see such a high percent of their initial TDA balance oset, even compared to self-reported liabilities, is
because a much higher percent of self-reported liabilities are collected through subsequent payments. Taxpayers who
receive AUR assessments may also be more likely to receive future refunds, since these taxpayers are oen wage earners
who have their income tax withheld by the payer.
Quantify how penalty and interest cause the liability from a tax assessment to increase the total balance due.
At rst glance, it appears that penalties and interest have been declining since . However, the signicant abatement
rate of the initial liability masks the increase in the balance due attributable to penalties and interest. Specically, abate-
ments have increased so the original TDA balance has experienced a greater decrease. erefore, penalties and interest
comprise a greater percentage of the amount actually determined due by the IRS. When one considers the amounts
of abatement from the initial TDA assessment, the percentage of the liability actually due to penalties and interest is
generally rising. From to , penalties have comprised a larger portion of the initial TDA balance the IRS has
assessed and determined due. For and , sucient time has not elapsed to realize the signicant eect of pen-
alties and interest. Figure illustrates this fact, showing that through , penalties and interest have continued to
constitute a larger percentage of the initial liability the IRS has determined due.
FIGURE 4. Percent of Liability Due Attributable to Penalties and Interest
0%
5%
10%
15%
20%
25%
30%
2003 2005 2007 2009 2011
Cumulative% %after3Years
IRS Collectibility Curve
From to , the portion of the initial assessment (actually due) resulting from penalties and interest in-
creased to almost a quarter of the initial liability. For later years, the portion on the initial TDA liability (actually due)
is likely to become an even higher percentage, although sucient time has not elapsed to experience the full impact of
penalties and interest.
As the IRS takes longer to collect liabilities, taxpayer burden will continue to increase, as taxpayers pay even larger
amounts of penalties and interest. e graph also shows that through the rst years aer TDA assignment, penalties
and interest remain relatively constant. However, as the IRS continues to resolve fewer TDAs, the percent of the initial
liability attributable to penalties and interest will continue to grow. By the th year of the collection statute, taxpayers
with TDAs originating in and owed more than twice the amount of penalties and interest they owed years
aer TDA assignment. For TDAs originating in , taxpayers owed more than three times the penalty and interest in
( years later) than they did in years aer the initial TDA. As the years progress, the IRS has assigned more ac-
counts to TDA status; however, for the years the -year collection statute has had sucient time to lapse, the average
amount of assessed penalty and interest has also increased for each TDA.
Determine the percent of liabilities abated by the IRS and if the percentage abated varies by the source of assessment.
Both dollars abated from the initial TDA assessment
27
and the percent of the initial balance abated have continued to
be higher than the rate, and they remain at an overall higher level, as indicated in Table .
TABLE 10. Percent of Initial TDA Balance Abated
28
Year Initial TDA Balance Amount Abated Percent Abated
2003 $15,326,191,192 $2,985,977,270 19%
2005 $25,996,084,845 $8,066,761,341 31%
2007 $40,678,451,308 $13,086,103,480 32%
2009 $41,987,700,518 $10,716,623,485 26%
2011 $42,926,217,917 $11,990,870,525 28%
e dollars abated continue to increase. e rate of abatement for is higher than in and , even
though the TDAs in have about two more years remaining on the collection statute. e abatement rate is down
slightly since ; however, less time has elapsed. e data suggest that Collection is continuing to focus signicant
resources on bad assessments.
We also explored the TDA dollars abated by the source of assessment, as indicated in Table . IRS substitute for
return assessments are the most likely to be abated.
For and , where years have elapsed since assignment
to a TDA, almost half of liability amounts have been abated.
TABLE 11. Percent of TDA Amount Abated, by Source of Assessment
Year
Self-Reported
Assessments
Substitute for
Return
Audit
Assessments
AUR
Assessments
Trust Fund
Recovery
Penalties
2003 6% 49% 15% 15% 39%
2005 6% 47% 12% 29% 40%
2007 12% 43% 14% 28% 35%
2009 9% 36% 13% 27% 28%
2011 16% 40% 19% 18% 29%
27
Dollars abated may include tax, penalty, and interest.
28
For TDAs initially assigned in 2003 and 2005, abatements are also attributable to the expiration of the 10-year collection statute.
29
is is presumably due to the fact that SFR assessments are based on the assumption that the taxpayer is single, claiming the standard deduction. at assessment prompts
some taxpayers to le a delinquent return, which documents a lower tax liability—thus, the abatement of the overstated liability. However, the remaining assessment could still
be very cost-eective to collect.
Beers, Hatch, Saldana, and Wilson
Obviously, substitute for return assessments are generating considerable rework for the IRS and may be preventing
the IRS from collecting additional subsequent payments on more productive work. IRS should ensure substitute for
return assessments are at least as cost-eective as other types of assessments and review current procedures to identify
revisions that could improve productivity.
e abatement rate of AUR assessments has also increased signicantly since , possibly implying that the IRS
is selecting more cases for AUR assessments, even though it is less certain that the taxpayer is liable for the additional
tax. Trust Fund Recovery Penalties (TFRP) have an abatement rate almost as high as that of substitute for return assess-
ments. However, TFRP assessments may have necessarily high abatement rates because the IRS abates the liability, as it
is paid by the underlying corporation or other responsible ocers.
Examine the percentage of cases resolved during the 10-year collection statute.
We examined the percentage of cases completely resolved within the usual -year collection statute. Overall, the IRS
completely resolved nearly percent of the cases reaching TDA status in and by the ninth year of the col-
lection statute.
30
e percentage of cases closed in the th year of collection statute increases signicantly because li-
abilities are being abated in full as the collection statute expires.
31
Although more time remains on the collection statute
for TDAs assigned in more recent years through equivalent periods of elapsed time, the percent of the balance due
collected has been declining from earlier years.
32
is information is illustrated by Table .
TABLE 12. Cumulative Closure Rate
Elapsed Years 2003 2005 2007 2009 2011
1 23% 25% 27% 21% 25%
2 38% 39% 40% 33% 37%
3 50% 49% 47% 41% 45%
4 58% 56% 53% 48% 48%
5 65% 61% 58% 52%
6 69% 65% 62% 54%
7 73% 68% 65%
8 76% 71% 66%
9 80% 74%
10 95% 80%
ough the IRS resolves most TDA modules, at least one-third of the total dollar amount of the liabilities remains
years aer a delinquency reaches TDA status, as illustrated in Figure .
e overall high closure rate is undoubtedly because, as discussed earlier, the vast majority of modules owe no
more than ,. e IRS is generally eective at collecting these smaller liabilities through subsequent payments and
osets. e data also indicate that the percentage of the total liability collected, including penalties and interest, has
been declining since , although the rate of liability growth due to penalties and interest has increased.
As the closure rate has generally declined from to , the volume of TDA cases remaining open has contin-
ued to increase. Table shows the volume of cases still open since the liability was assigned to TDA status.
30
e liability may be completely resolved because: (a) the taxpayer paid the liability in full, including penalties and interest; (b) the IRS may have determined the liability was
incorrect and abated all or part of it; or (c) the IRS may have accepted an oer to compromise the tax liability for less than the full amount.
31
e closure rates depicted are for TDA liabilities. Since time has elapsed between the assessment of a liability and when the IRS assigns it to TDA status, the collection
statute generally expires during the 10th year since the liability reached TDA status (rather than at the end of the 10th year). Certain actions, such as the consideration of an
installment agreement, oer in compromise, or bankruptcy proceeding may extend the collection statute. Additionally, the taxpayer may voluntarily extend the collection
statute, usually to pursue a long-term installment agreement.
32
e closure rate for 2011 is higher than the rate in 2009 until the fourth year.
33
We used the fourth year of the collection statute for an even comparison.
IRS Collectibility Curve
FIGURE 5. Liability Remaining Four Years After TDA Issued
0%
5%
10%
15%
20%
25%
30%
35%
40%
45%
2003 2005 2007 2009 2011
InitialYearofTDAAssignment
TABLE 13. Percent of Cases Remaining Open by Years Since Becoming a TDA
Year Since
TDA Issued
2003 2005 2007 2009 2011
1 77% 75% 73% 79% 75%
2 62% 61% 60% 67% 63%
3 50% 51% 53% 59% 55%
4 42% 44% 47% 52% 52%
5 35% 39% 42% 48%
6 31% 35% 38% 46%
7 27% 32% 35%
8 24% 29% 34%
9 20% 26%
10 5% 20%
e volume of open cases in is many times larger than in . A signicant reason for this is that the volume
of new TDAs has increased so dramatically; another might be the declining trend of Collection stang. e table
demonstrates that the closure rate drops as the years progress aer a module reaches TDA status. While one-h or
less of the cases remained unresolved at the time of collection statute expiration for new TDAs from to , it is
likely that nearly a third of the new TDAs since will remain unresolved at the time of collection statute expiration.
Determine if the percentage of TDA dollars collected varies by Collection channel
e dollars collected and abated do vary by Collection channel. Table shows that the largest percentage of dollars
collected by subsequent payments and refund osets were garnered by ACS.
Beers, Hatch, Saldana, and Wilson
TABLE 14. Percent of Initial Balance Satised by Payments, Offsets, or Abatements
Year
ACS
Queue
Collection Field Function
Percent of Initial Balance Percent of Initial Balance Percent of Initial Balance
Collected by
Subsequent
Payments
Collected
by Offsets
Abated
Collected by
Subsequent
Payments
Collected
by Offsets
Abated
Collected by
Subsequent
Payments
Collected
by Offsets
Abated
2003 44% 22% 14%
29% 6% 23%
32% 6% 28%
2005 40% 21% 21% 17% 5% 37% 21% 6% 39%
2007 39% 25% 19% 11% 4% 36% 13% 5% 41%
2009 30% 16% 20% 9% 4% 27% 13% 5% 32%
2011 26% 15% 16%
8% 3% 37%
12% 2% 42%
e table shows that ACS dollars collected from subsequent payments have continued to decrease since . For
liabilities reaching TDA status since , additional time remains to receive subsequent payments and osets; how-
ever, the percent of the liability collected has increased by no more than percent in the nal years of the collection
statute. erefore, it seems likely ACS will collect a signicantly smaller percentage of the initial TDA balance than in
. e trend of the IRS collecting fewer dollars through subsequent payments is even stronger for the cases assigned
to the queue and CFf.
Osets as a percentage of the initial TDA balance due actually increased slightly for new ACS TDAs from to
, but then drastically decreased in and . For TDAs assigned to the queue or CFf, osets as a percent of the
initial TDA balance have generally remained constant, though garnering a relatively small percent of the initial TDA
balance.
Abatements of at least some of the initial TDA balance are relatively high in all three functions with TDA inventory.
However, the percentage of the initial TDA balance abated is higher in the queue than in ACS and even higher in CFf.
In fact, about a third of the initial balances of the TDAs assigned to CFf are abated. is means that CFf personnel are
spending a signicant portion of their time resolving problem assessments. Accordingly, a review of current procedures
might identify ways that these cases could be worked more eectively.
Aer removing abatements from the initial balance due and when considering only the rst years since the case
reached TDA status,
the percent of initial TDA dollars collected is signicantly higher, as indicated by Table .
TABLE 15. Percent of Initial TDA Balance After Abatements
Collected by Payments and Offsets After First Six Years in
TDA Status
Year ACS Queue CFf
2003 67% 39% 45%
2005 69% 28% 35%
2007 73% 20% 26%
2009 58% 19% 26%
Although Table combines dollars collected through subsequent payments and osets, the total amount collected
becomes a larger percent of the actual balance due, since abatements are excluded. is is particularly noticeable in CFf,
which consistently has the highest percentage of abatements when compared to the other TDA collection channels. In
general, the percent of the initial TDA balance collected has declined since .
Conclusions and Summary
e IRS is more successful at collecting liabilities soon aer TDA assignment. is result is similar to the experience
of private collection agencies. Dollars do continue to be collected throughout the life of the -year collection stat-
ute period; however, the payment rate slows signicantly. As one might expect, the IRS is also more successful in its
34
We have removed TDAs originating in 2011 since sucient time has not elapsed to examine collections 6 years later.
IRS Collectibility Curve
collection of self-reported assessments and smaller TDA balances. e IRS continues to deal with a high number of
bad assessments that hamper its TDA collections. While we are heartened by the IRS’s willingness to abate improper
(or uncollectible) assessments, we wonder how many taxpayers pay assessments for which they are not liable, before
the IRS even assigns the delinquency to TDA status. We have distilled the ndings from the nine objectives into nine
specic conclusions.
. Dollars collected in aggregate and as a percentage of the balance due decrease signicantly during the rst
years aer the IRS assigns a liability to TDA status. e decline in the module balance also slows signicantly
during these rst years.
. When continuing to look at the collection of liabilities aer the third year of the initial TDA assignment, collec-
tions continue to dwindle, and the reduction in the module balance declines almost completely by the expira-
tion of the collection statute.
. Overall, dollars collected through the osets of other overpayments are signicantly less than dollars collected
through subsequent payments. However, dollars collected through osets decrease much less precipitously than
dollars collected from subsequent payments as time elapses from the initial TDA assignment.
. Delinquent modules with balances due not in excess of , comprise the vast majority of TDAs. However,
over percent of the total amount due resides with TDAs with balances greater than ,. e IRS collects
both a higher percentage of subsequent payments and osets in the lowest balance due categories. Collections
and osets as a percentage of the balance due progressively decrease as the balance due rises.
. e percentage of the TDA balance collected is signicantly greater for self-reported liabilities than when the
IRS makes additional assessments. However, AUR assessments result in a greater percentage of dollars collected
through osets.
. Penalty and interest signicantly increase the balance owed by taxpayers, particularly when the underlying bal-
ance remains unresolved for several years.
. e IRS abates between a quarter and a third of TDA liabilities and to percent of its substitute for return
assessments. It also abates a high proportion of AUR assessments.
. e IRS completely resolves most of its TDA modules within the -year collection statute, with a resolution
rate of about percent for TDAs assigned in and . Unfortunately, the percent of TDAs resolved has
generally declined thereaer. Additionally, the balance owed on these delinquencies has been reduced by less
than percent.
. ACS realizes the largest percentage of TDA balances collected by subsequent payment and oset. While the
percentage of dollars abated is high in all TDA collection channels, the abatement rates are signicantly higher
in the queue and CFf than in ACS. However, even controlling for abatements, ACS collects a greater percentage
of the liabilities assigned to it compared to the other TDA functions.
Possible Future Analyses
We hope to perform a similar analysis on Business Master File (BMF) TDAs. A proper examination of the TDA process
must include both IMF and BMF delinquencies. We also want to explore dollars collected and abated, which are gen-
erated by IRS additional assessments prior to TDA assignment. Finally, we would like to explore the eect of not only
penalty and interest assessments, but also their accruals. In the case of unpaid liabilities, accrued penalties and interest
are oen never assessed. IRS TDA collections occur within a complex and dynamic environment, and this subject will
undoubtedly benet from many other avenues of study.
35
No active collection occurs on cases in the collection queue; however, osets still occur and previous IRS notices may continue to generate payments even while the TDA is
assigned to the collection queue.
Beers, Hatch, Saldana, and Wilson
TABLE A-1. TDA Modules, Balances Due, Dollars Collected by Subsequent Payments and Offsets, Assessed Penalties, Assessed
Interest, and Abatements
Calendar Year
Balance
at TDA
Assignment
Count
of Initial
TDAs
Elapsed
Years
TDAs
Open at
End of
Year
Initial Balance
of TDAs Open
at Beginning of
Year
Balance of TDAs
Open at End of
Year
Subsequent
Payments
Offsets Penalty Interest Abated
2003
$15,326,191,192
2,025,755
1 1,558,504 $12,202,854,742 $12,321,333,646 ($1,786,425,808) ($611,820,128) $89,119,656
$82,701,617 ($1,106,542,945)
2 1,249,051 $10,705,878,192 $10,370,295,098 ($2,953,192,068) ($1,004,364,248) $269,670,662
$201,012,229 ($1,829,914,155)
3 1,016,996 $9,603,254,459 $8,841,346,757 ($3,801,679,211) ($1,277,319,134) $585,337,406
$326,153,660 ($2,224,684,772)
4 847,927 $8,947,277,180 $7,687,319,274 ($4,416,806,933) ($1,483,618,443) $739,002,105
$452,949,424 ($2,488,570,542)
5 714,507 $8,477,650,276 $6,877,286,149 ($4,819,728,794) ($1,684,130,906) $831,819,282
$576,698,445 ($2,684,022,516)
6 619,011 $8,148,690,214 $6,297,481,488 ($5,073,940,295) ($1,829,221,428) $889,248,536
$671,604,646 ($2,778,370,133)
7 548,004 $7,835,654,529 $5,800,613,947 ($5,270,506,889) ($1,933,592,477) $927,727,194
$753,409,760 ($2,862,189,720)
8 483,727 $7,522,186,532 $5,380,880,143 ($5,436,525,749) ($2,024,868,988) $958,856,995
$824,597,632 ($2,919,730,570)
9 414,757 $7,139,350,498 $4,956,881,909 ($5,577,901,284) ($2,101,141,358) $976,327,065
$886,788,555 ($2,957,500,657)
10 103,959 $2,715,523,009 $1,849,467,741 ($5,701,245,981) ($2,150,746,245) $986,076,244
$1,035,691,869 ($2,985,977,270)
2004
$17,476,051,716
2,006,000
1 1,506,593 $14,153,844,859 $14,143,137,643 ($2,501,899,078) ($747,349,755) $149,376,200
$105,452,460 ($1,584,920,917)
2 1,203,022 $12,549,660,891 $11,975,498,939 ($3,754,805,143) ($1,154,990,432) $452,808,938
$226,818,884 ($2,569,660,336)
3 992,048 $11,521,880,241 $10,436,948,936 ($4,596,320,388) ($1,439,730,392) $669,618,362
$360,478,204 ($3,187,925,790)
4 828,892 $10,878,654,148 $9,336,449,727 ($5,148,678,296) ($1,702,363,549) $801,491,959
$496,624,078 ($3,538,338,134)
5 715,665 $10,351,952,753 $8,504,213,714 ($5,503,793,070) ($1,894,349,784) $883,250,592
$608,266,879 ($3,739,317,881)
6 633,569 $10,003,813,674 $7,901,689,312 ($5,772,219,032) ($2,022,786,186) $938,660,871
$703,039,219 ($3,862,272,262)
7 566,207 $9,700,168,602 $7,385,215,277 ($5,988,599,885) ($2,135,679,620) $982,062,268
$786,224,962 ($3,957,635,608)
8 505,348 $9,403,151,087 $6,952,037,321 ($6,172,225,808) ($2,228,208,053) $1,007,015,975
$861,745,767 ($4,037,658,221)
9 439,849 $8,950,989,408 $6,427,925,814 ($6,340,470,292) ($2,302,166,002) $1,037,347,823
$1,281,890,856 ($4,094,826,942)
10 112,388 $2,958,725,002 $2,161,305,313 ($6,460,997,698) ($2,354,540,305) $1,047,975,390
$2,042,654,002 ($4,150,004,992)
2005
$25,996,084,845
2,607,542
1 1,955,638 $20,955,172,357 $20,872,616,207 ($2,990,840,093) ($936,838,872) $307,557,342
$145,216,764 ($3,513,228,092)
2 1,592,045 $18,585,020,738 $17,657,416,604 ($4,334,974,344) ($1,446,837,231) $670,504,187
$302,527,494 ($5,507,789,892)
3 1,326,084 $17,390,016,757 $15,759,106,685 ($5,167,617,507) ($1,908,989,084) $902,564,484
$470,456,001 ($6,399,531,567)
4 1,146,071 $16,596,217,970 $14,423,464,446 ($5,703,405,817) ($2,239,561,550) $1,036,694,485
$620,049,022 ($6,880,716,807)
5 1,021,777 $15,982,934,958 $13,440,585,575 ($6,098,077,184) ($2,462,184,885) $1,125,512,272
$747,675,302 ($7,235,932,955)
6 920,443 $15,505,712,748 $12,629,990,619 ($6,439,393,580) ($2,653,438,207) $1,195,301,649
$866,792,903 ($7,585,208,018)
7 835,687 $15,067,568,527 $11,945,667,325 ($6,728,867,200) ($2,814,797,286) $1,238,566,723
$975,711,954 ($7,762,861,068)
8 759,818 $14,613,428,103 $11,290,987,893 ($6,981,187,587) ($2,940,382,649) $1,267,269,374
$1,574,319,150 ($7,934,958,417)
9 672,606 $14,138,685,088 $10,636,264,945 ($7,190,638,676) ($3,041,430,818) $1,287,987,437
$3,395,828,366 ($8,019,244,730)
10 509,936 $10,346,307,042 $7,790,616,336 ($7,314,258,218) ($3,086,529,497) $1,297,081,117
$3,728,401,948 ($8,066,761,341)
IRS Collectibility Curve
Table A-1. TDA Modules, Balances Due, Dollars Collected by Subsequent Payments and Offsets, Assessed Penalties, Assessed Interest,
and Abatements—Continued
Calendar Year
Balance at TDA
Assignment
Count
of Initial
TDAs
Elapsed Years
TDAs
Open at
End of
Year
Initial Balance
of TDAs Open
at Beginning of
Year
Balance of TDAs
Open at End of
Year
Subsequent
Payments
Offsets Penalty Interest Abated
2006
$30,351,736,552
2,957,590
1
2,203,545
$24,284,699,486
$24,382,428,297 ($3,781,436,023) ($1,205,226,894) $309,230,189 $209,887,340 ($4,028,543,955)
2
1,780,405
$22,047,122,624
$21,134,976,827 ($5,087,188,574) ($1,963,812,846) $709,216,745 $407,185,852 ($6,082,017,996)
3
1,509,512
$20,820,896,493
$19,211,320,024 ($5,869,908,534) ($2,487,104,515) $946,574,128 $582,951,565 ($6,954,956,357)
4
1,328,595
$19,861,906,645
$17,796,978,467 ($6,419,325,485) ($2,827,975,036) $1,094,243,027 $732,786,143 ($7,563,744,203)
5
1,186,108
$19,080,518,237
$16,650,119,657 ($6,894,884,536) ($3,116,809,435) $1,212,432,154 $876,720,366 ($8,037,931,474)
6
1,069,254
$18,450,044,275
$15,650,453,262 ($7,275,730,544) ($3,348,658,925) $1,284,228,928 $1,003,755,551 ($8,323,694,663)
7
972,478
$17,805,347,394
$14,741,986,913 ($7,609,546,792) ($3,522,136,383) $1,332,557,514 $1,639,089,778 ($8,634,838,759)
8
884,575
$17,271,468,616
$13,932,332,131 ($7,883,737,061) ($3,667,649,412) $1,364,801,580 $3,675,241,137 ($8,832,844,829)
9
846,817
$17,053,947,088
$13,589,243,327 ($8,056,543,080) ($3,741,238,520) $1,378,720,590 $4,248,993,113 ($8,941,304,377)
10
846,817
$17,053,947,088
$13,589,243,327 ($8,063,991,533) ($3,746,160,529) $1,379,211,905 $4,258,974,459 ($8,944,717,308)
2007
$40,678,451,308
3,740,790
1
2,740,824
$32,849,020,598
$32,783,285,129 ($3,664,816,262) ($1,704,605,008) $409,689,710 $244,845,100 ($6,153,964,029)
2
2,263,145
$29,935,148,423
$28,948,279,752 ($4,995,256,277) ($2,578,789,150) $928,407,071 $442,246,287 ($8,835,026,272)
3
1,964,827
$28,301,134,533
$26,531,718,898 ($5,902,253,282) ($3,123,531,076) $1,225,542,214 $619,234,800 ($10,248,579,985)
4
1,740,283
$26,943,462,391
$24,561,583,882 ($6,622,550,732) ($3,557,488,509) $1,439,733,283 $784,185,932 ($11,226,517,587)
5
1,563,477
$25,668,240,755
$22,940,259,164 ($7,222,864,085) ($3,909,144,483) $1,564,479,638 $939,931,827 ($11,990,004,660)
6
1,423,312
$24,806,106,219
$21,617,558,053 ($7,740,223,075) ($4,171,160,348) $1,658,992,874 $1,578,574,745 ($12,433,762,035)
7
1,309,349
$24,032,849,448
$20,502,316,740 ($8,157,636,602) ($4,376,959,658) $1,722,429,524 $4,085,368,501 ($12,878,254,066)
8
1,266,294
$23,740,426,822
$20,017,141,706 ($8,430,113,249) ($4,487,871,926) $1,753,835,888 $4,860,034,842 ($13,076,870,319)
9
1,266,294
$23,740,426,822
$20,017,141,706 ($8,437,945,803) ($4,493,500,687) $1,760,082,415 $4,884,033,478 ($13,086,103,480)
10
1,266,294
$23,740,426,822
$20,017,141,706 ($8,437,945,803) ($4,493,500,687) $1,760,082,415 $4,884,033,478 ($13,086,103,480)
2008
$36,483,193,583
3,590,831
1
2,649,311
$29,335,325,217
$29,514,274,945 ($3,413,545,809) ($1,878,405,331) $403,291,535 $202,209,490 ($4,823,470,102)
2
2,208,374
$26,773,821,008
$26,230,469,576 ($4,811,813,396) ($2,701,802,914) $890,503,910 $370,626,083 ($6,864,923,888)
3
1,901,082
$24,935,784,088
$23,876,251,293 ($5,816,581,381) ($3,295,841,646) $1,269,411,583 $528,307,655 ($8,035,065,577)
4
1,670,837
$23,366,011,300
$21,993,850,951 ($6,600,450,645) ($3,744,521,767) $1,495,474,859 $681,365,525 ($8,780,833,412)
5
1,496,220
$22,207,414,517
$20,447,570,975 ($7,255,716,053) ($4,064,995,130) $1,632,099,721 $1,173,686,878 ($9,281,979,287)
6
1,359,759
$21,073,271,206
$18,980,116,872 ($7,761,069,616) ($4,306,986,432) $1,720,257,087 $2,873,881,178 ($9,741,262,882)
7
1,312,693
$20,740,005,590
$18,478,220,702 ($8,046,513,083) ($4,411,125,862) $1,755,943,129 $3,458,126,788 ($9,937,104,100)
8
1,312,693
$20,740,005,590
$18,478,220,702 ($8,042,788,704) ($4,413,244,389) $1,756,334,243 $3,461,084,068 ($9,939,486,398)
9
1,312,693
$20,740,005,590
$18,478,220,702 ($8,042,788,704) ($4,413,244,389) $1,756,334,243 $3,461,084,068 ($9,939,486,398)
10
1,312,693
$20,740,005,590
$18,478,220,702 ($8,042,788,704) ($4,413,244,389) $1,756,334,243 $3,461,084,068 ($9,939,486,398)
Beers, Hatch, Saldana, and Wilson
Table A-1. TDA Modules, Balances Due, Dollars Collected by Subsequent Payments and Offsets, Assessed Penalties, Assessed Interest,
and Abatements—Continued
Calendar
Year
Balance at TDA
Assignment
Count
of Initial
TDAs
Elapsed Years
TDAs
Open at
End of
Year
Initial Balance
of TDAs Open
at Beginning of
Year
Balance of TDAs
Open at End of
Year
Subsequent
Payments
Offsets Penalty Interest Abated
2009
$41,987,700,518
3,625,853
1 2,855,031 $34,910,079,884 $35,332,522,291 ($3,631,938,674) ($1,725,467,681) $534,920,665 $153,433,427 ($5,003,814,841)
2 2,436,301 $31,718,637,329 $31,581,177,384 ($5,307,444,529) ($2,621,430,430) $1,107,107,550 $296,769,692 ($7,490,662,803)
3 2,132,368 $29,367,116,987 $28,767,291,989 ($6,524,263,263) ($3,251,623,753) $1,561,792,804 $447,222,002 ($8,852,151,280)
4 1,902,942 $27,478,019,214 $26,495,824,596 ($7,469,086,900) ($3,698,507,804) $1,824,680,818 $951,475,433 ($9,784,258,243)
5 1,727,894 $26,092,408,873 $24,608,525,544 ($8,215,663,586) ($4,037,187,165) $1,996,145,246 $2,667,410,510 ($10,433,401,857)
6 1,674,774 $25,649,101,721 $23,922,424,354 ($8,595,196,469) ($4,171,691,809) $2,071,626,158 $3,234,730,639 ($10,715,471,960)
7 1,674,774 $25,649,101,721 $23,922,424,354 ($8,598,477,760) ($4,173,553,636) $2,071,942,891 $3,236,409,717 ($10,716,623,485)
8 1,674,774 $25,649,101,721 $23,922,424,354 ($8,598,477,760) ($4,173,553,636) $2,071,942,891 $3,236,409,717 ($10,716,623,485)
9 1,674,774 $25,649,101,721 $23,922,424,354 ($8,598,477,760) ($4,173,553,636) $2,071,942,891 $3,236,409,717 ($10,716,623,485)
10 1,674,774 $25,649,101,721 $23,922,424,354 ($8,598,477,760) ($4,173,553,636) $2,071,942,891 $3,236,409,717 ($10,716,623,485)
2010
$45,704,392,188
4,150,283
1 3,104,902 $36,225,946,333 $36,770,145,599 ($3,900,220,431) ($2,003,251,896) $577,836,901 $145,097,158 ($6,856,757,918)
2 2,576,011 $32,624,372,420 $32,514,634,453 ($5,661,580,107) ($2,941,601,479) $1,178,134,280 $281,162,628 ($9,488,141,786)
3 2,231,853 $29,863,854,205 $29,468,592,163 ($6,925,540,407) ($3,556,525,164) $1,676,116,937 $652,063,333 ($11,204,940,751)
4 1,984,379 $28,100,821,406 $27,193,787,060 ($7,871,884,638) ($4,003,121,592) $1,948,303,588 $1,942,072,455 ($12,079,326,237)
5 1,907,417 $27,527,977,964 $26,369,110,984 ($8,443,668,673) ($4,228,019,965) $2,071,093,184 $2,535,673,602 ($12,484,578,501)
6 1,907,417 $27,527,977,964 $26,369,110,984 ($8,460,865,513) ($4,240,011,358) $2,073,829,920 $2,545,381,557 ($12,492,491,633)
7 1,907,417 $27,527,977,964 $26,369,110,984 ($8,460,865,513) ($4,240,011,358) $2,073,829,920 $2,545,381,557 ($12,492,491,633)
8 1,907,417 $27,527,977,964 $26,369,110,984 ($8,460,865,513) ($4,240,011,358) $2,073,829,920 $2,545,381,557 ($12,492,491,633)
9 1,907,417 $27,527,977,964 $26,369,110,984 ($8,460,865,513) ($4,240,011,358) $2,073,829,920 $2,545,381,557 ($12,492,491,633)
10 1,907,417 $27,527,977,964 $26,369,110,984 ($8,460,865,513) ($4,240,011,358) $2,073,829,920 $2,545,381,557 ($12,492,491,633)
2011
$42,926,217,917
4,024,360
1 3,020,150 $34,032,316,693 $34,795,749,849 ($3,800,144,148) ($1,797,902,891) $516,330,747 $126,728,719 ($6,755,704,392)
2 2,522,271 $29,319,068,318 $29,792,646,489 ($5,548,247,612) ($2,676,941,031) $1,078,438,736 $387,516,960 ($10,289,591,480)
3 2,196,229 $27,055,074,385 $27,132,375,863 ($6,725,846,404) ($3,273,238,113) $1,511,675,025 $1,265,063,880 ($11,484,501,895)
4 2,097,838 $26,304,398,711 $26,094,655,803 ($7,414,305,809) ($3,569,753,914) $1,691,974,661 $1,749,969,482 ($11,981,924,704)
5 2,097,838 $26,304,398,711 $26,094,655,803 ($7,435,121,689) ($3,583,172,056) $1,697,342,413 $1,760,693,864 ($11,990,870,525)
6 2,097,838 $26,304,398,711 $26,094,655,803 ($7,435,121,689) ($3,583,172,056) $1,697,342,413 $1,760,693,864 ($11,990,870,525)
7 2,097,838 $26,304,398,711 $26,094,655,803 ($7,435,121,689) ($3,583,172,056) $1,697,342,413 $1,760,693,864 ($11,990,870,525)
8 2,097,838 $26,304,398,711 $26,094,655,803 ($7,435,121,689) ($3,583,172,056) $1,697,342,413 $1,760,693,864 ($11,990,870,525)
9 2,097,838 $26,304,398,711 $26,094,655,803 ($7,435,121,689) ($3,583,172,056) $1,697,342,413 $1,760,693,864 ($11,990,870,525)
10 2,097,838 $26,304,398,711 $26,094,655,803 ($7,435,121,689) ($3,583,172,056) $1,697,342,413 $1,760,693,864 ($11,990,870,525)
IRS Collectibility Curve
Table A-1. TDA Modules, Balances Due, Dollars Collected by Subsequent Payments and Offsets, Assessed Penalties, Assessed Interest,
and Abatements—Continued
Calendar
Year
Balance at TDA
Assignment
Count
of Initial
TDAs
Elapsed Years
TDAs
Open at
End of
Year
Initial Balance
of TDAs Open
at Beginning of
Year
Balance of TDAs
Open at End of
Year
Subsequent
Payments
Offsets Penalty Interest Abated
2012
$40,571,783,915
3,958,801
1 3,042,337 $32,742,725,029 $33,739,786,846 ($3,603,072,713) ($1,763,779,947) $543,964,069 $180,683,705 ($5,183,970,519)
2 2,560,958 $28,855,402,233 $29,385,315,074 ($5,293,758,985) ($2,675,662,462) $1,075,108,307 $758,149,918 ($7,945,451,495)
3 2,431,227 $27,700,178,097 $28,084,991,830 ($6,264,144,364) ($3,108,350,689) $1,401,487,635 $1,269,916,084 ($8,842,682,967)
4 2,431,227 $27,700,178,097 $28,084,991,830 ($6,290,918,513) ($3,122,370,872) $1,405,404,179 $1,276,993,550 ($8,856,749,351)
5 2,431,227 $27,700,178,097 $28,084,991,830 ($6,290,918,513) ($3,122,370,872) $1,405,404,179 $1,276,993,550 ($8,856,749,351)
6 2,431,227 $27,700,178,097 $28,084,991,830 ($6,290,918,513) ($3,122,370,872) $1,405,404,179 $1,276,993,550 ($8,856,749,351)
7 2,431,227 $27,700,178,097 $28,084,991,830 ($6,290,918,513) ($3,122,370,872) $1,405,404,179 $1,276,993,550 ($8,856,749,351)
8 2,431,227 $27,700,178,097 $28,084,991,830 ($6,290,918,513) ($3,122,370,872) $1,405,404,179 $1,276,993,550 ($8,856,749,351)
9 2,431,227 $27,700,178,097 $28,084,991,830 ($6,290,918,513) ($3,122,370,872) $1,405,404,179 $1,276,993,550 ($8,856,749,351)
10 2,431,227 $27,700,178,097 $28,084,991,830 ($6,290,918,513) ($3,122,370,872) $1,405,404,179 $1,276,993,550 ($8,856,749,351)
Beers, Hatch, Saldana, and Wilson
TABLE A-2. TDA Modules, Balances Due, Dollars Collected by Subsequent Payments and Offsets, Assessed Penalties, Assessed
Interest, and Abatements by Balance Due Ranges
Calendar
Year
Description
$1
to
$1,000
$1,001
to
$2,000
$2,001
to
$5,000
$5,001
to
$10,000
$10,001
to
$25,000
Greater Than
$25,000
2003
TDA Count
451,712 505,146 565,164 250,331 160,431 92,971
Initial Balance Due $240,828,346 $740,649,611 $1,793,135,994 $1,745,405,984 $2,446,859,748 $8,359,311,510
Subsequent Payments ($159,645,920) ($359,532,161) ($886,819,407) ($845,113,111) ($1,054,887,316) ($2,395,248,066)
Offset ($120,551,135) ($323,517,417) ($625,523,335) ($382,757,722) ($316,904,898) ($381,491,738)
Penalty $33,446,962 $78,987,494 $172,236,063 $141,164,346 $168,647,485 $391,593,894
Interest $45,822,418 $91,605,397 $204,538,984 $171,753,801 $186,241,347 $335,729,923
Abated ($27,475,487) ($43,593,443) ($146,029,262) ($188,258,429) ($333,475,486) ($2,247,145,162)
2004
TDA Count 423,322 454,156 576,996 259,361 175,488 116,677
Initial Balance Due $226,310,020 $677,561,180 $1,825,708,766 $1,813,925,576 $2,685,068,369 $10,247,477,805
Subsequent Payments ($175,904,106) ($375,205,472) ($982,626,633) ($934,209,391) ($1,225,047,057) ($2,768,005,039)
Offset ($121,702,024) ($321,705,919) ($694,321,067) ($425,213,207) ($369,848,986) ($421,749,103)
Penalty $31,504,743 $75,081,251 $176,833,442 $144,534,463 $180,793,631 $439,227,860
Interest $49,458,179 $105,365,867 $277,857,329 $269,972,536 $358,344,029 $981,656,061
Abated ($23,945,856) ($47,587,534) ($162,623,959) ($224,236,892) ($456,718,448) ($3,234,892,303)
2005
TDA Count 467,988 561,662 762,610 388,628 254,399 172,255
Initial Balance Due $250,772,306 $832,921,777 $2,462,466,838 $2,713,904,406 $3,886,596,037 $15,849,423,481
Subsequent Payments ($197,408,638) ($453,485,724) ($1,226,197,456) ($1,188,786,059) ($1,422,684,108) ($2,825,696,234)
Offset ($138,643,683) ($412,526,218) ($935,264,928) ($616,224,119) ($496,862,712) ($487,007,838)
Penalty $35,438,062 $86,715,864 $216,494,334 $189,194,145 $232,769,822 $536,468,890
Interest $59,999,279 $140,495,631 $436,422,558 $502,988,977 $683,406,500 $1,905,089,002
Abated ($30,966,042) ($62,829,089) ($266,610,631) ($409,931,148) ($766,502,708) ($6,529,921,723)
2006
TDA Count 509,337 615,280 867,067 474,879 299,498 191,529
Initial Balance Due $271,505,543 $909,001,299 $2,834,634,772 $3,307,189,504 $4,562,501,833 $18,466,903,602
Subsequent Payments ($252,565,017) ($472,447,644) ($1,296,013,518) ($1,308,078,558) ($1,546,630,399) ($3,188,256,398)
Offset ($150,453,775) ($458,496,094) ($1,109,332,469) ($813,619,177) ($606,206,985) ($608,052,027)
Penalty $36,272,026 $87,550,652 $235,367,768 $217,417,225 $250,427,660 $552,176,574
Interest $69,173,136 $151,472,115 $476,431,996 $576,607,004 $768,858,956 $2,216,431,253
Abated ($46,693,380) ($77,413,359) ($308,977,379) ($480,897,741) ($847,379,103) ($7,183,356,346)
IRS Collectibility Curve
TABLE A-2. TDA Modules, Balances Due, Dollars Collected by Subsequent Payments and Offsets, Assessed Penalties, Assessed
Interest, and Abatements by Balance Due Ranges—Continued
Calendar
Year
Description
$1
to
$1,000
$1,001
to
$2,000
$2,001
to
$5,000
$5,001
to
$10,000
$10,001
to
$25,000
Greater Than
$25,000
2007
TDA Count 781,534 666,064 1,006,717 616,892 408,744 260,839
Initial Balance Due $449,269,937 $978,486,020 $3,313,143,007 $4,309,521,457 $6,214,721,121 $25,413,309,766
Subsequent Payments ($271,255,779) ($440,895,663) ($1,317,912,732) ($1,436,890,739) ($1,656,381,839) ($3,314,609,051)
Offset ($275,425,703) ($501,704,901) ($1,240,557,318) ($1,002,620,280) ($735,452,110) ($737,740,375)
Penalty $52,681,418 $88,781,235 $249,790,312 $252,451,642 $304,732,788 $811,645,020
Interest $86,193,479 $145,245,793 $486,817,479 $630,865,633 $884,120,071 $2,650,791,023
Abated ($129,967,848) ($94,765,806) ($402,625,097) ($679,848,856) ($1,203,496,891) ($10,575,398,982)
2008
TDA Count 731,451 670,937 1,016,335 550,220 385,289 236,599
Initial Balance Due $414,830,731 $990,497,117 $3,284,041,388 $3,845,368,753 $5,906,630,325 $22,041,825,269
Subsequent Payments ($233,650,205) ($403,601,852) ($1,205,681,275) ($1,232,376,624) ($1,579,199,205) ($3,388,279,541)
Offset ($243,479,900) ($497,742,738) ($1,214,494,488) ($881,503,108) ($721,414,352) ($854,609,803)
Penalty $48,985,319 $87,949,930 $244,002,549 $246,084,994 $317,910,922 $811,400,529
Interest $69,958,224 $121,666,892 $380,821,867 $454,035,901 $670,573,651 $1,764,027,532
Abated ($74,950,472) ($84,664,150) ($337,726,625) ($498,468,833) ($991,149,552) ($7,952,526,766)
2009
TDA Count 520,936 596,584 1,038,156 697,680 479,893 292,604
Initial Balance Due $290,826,653 $907,622,403 $3,388,475,005 $4,874,905,595 $7,345,952,997 $25,179,917,864
Subsequent Payments ($168,308,125) ($365,851,165) ($1,169,531,683) ($1,324,853,213) ($1,714,583,628) ($3,855,349,945)
Offset ($133,042,345) ($362,615,410) ($1,039,704,190) ($936,893,572) ($753,063,838) ($948,234,281)
Penalty $35,240,420 $77,982,626 $246,319,981 $277,035,867 $375,311,428 $1,060,052,569
Interest $43,615,381 $87,002,543 $304,084,837 $412,359,663 $623,590,625 $1,765,756,667
Abated ($58,131,912) ($79,760,319) ($365,636,375) ($663,016,312) ($1,322,675,570) ($8,227,402,996)
2010
TDA Count 840,148 808,468 1,121,844 647,137 453,016 279,670
Initial Balance Due $490,472,989 $1,199,142,789 $3,618,771,867 $4,555,543,493 $6,918,572,956 $28,921,888,093
Subsequent Payments ($254,834,586) ($456,192,529) ($1,168,128,274) ($1,194,754,484) ($1,618,245,117) ($3,768,710,523)
Offset ($240,509,528) ($508,265,653) ($1,143,358,182) ($810,941,332) ($678,453,146) ($858,483,517)
Penalty $56,440,339 $101,938,493 $258,977,602 $252,636,859 $349,515,692 $1,054,320,934
Interest $47,796,130 $86,595,116 $244,066,722 $302,628,434 $445,969,685 $1,418,325,469
Abated ($51,894,751) ($87,114,213) ($305,230,442) ($536,651,544) ($1,096,370,320) ($10,415,230,363)
Beers, Hatch, Saldana, and Wilson
TABLE A-2. TDA Modules, Balances Due, Dollars Collected by Subsequent Payments and Offsets, Assessed Penalties, Assessed
Interest, and Abatements by Balance Due Ranges—Continued
Calendar
Year
Description
$1
to
$1,000
$1,001
to
$2,000
$2,001
to
$5,000
$5,001
to
$10,000
$10,001
to
$25,000
Greater Than
$25,000
2011
TDA Count 825,154 754,679 1,136,688 639,600 422,102 246,137
Initial Balance Due $480,421,472 $1,117,857,159 $3,718,666,067 $4,484,256,769 $6,436,680,632 $26,688,335,819
Subsequent Payments ($218,477,840) ($383,128,439) ($1,047,791,886) ($1,060,125,297) ($1,423,029,355) ($3,302,568,871)
Offset ($224,505,778) ($430,557,063) ($1,011,715,750) ($706,990,836) ($567,489,241) ($641,913,390)
Penalty $46,648,243 $81,026,407 $226,937,654 $209,268,186 $285,370,582 $848,091,340
Interest $36,845,747 $62,819,645 $182,749,854 $215,524,482 $308,187,021 $954,567,115
Abated ($78,541,023) ($83,847,322) ($322,574,937) ($595,578,698) ($922,707,731) ($9,987,620,814)
2012
TDA Count 797,290 747,214 1,171,478 612,676 396,654 233,489
Initial Balance Due $461,112,482 $1,110,719,485 $3,825,438,842 $4,282,481,148 $5,990,784,717 $24,901,247,241
Subsequent Payments ($177,373,252) ($303,891,260) ($820,145,806) ($813,093,192) ($1,122,292,940) ($3,054,122,063)
Offset ($179,411,721) ($380,643,270) ($941,082,680) ($607,840,547) ($465,246,196) ($548,146,459)
Penalty $39,838,543 $63,657,332 $175,282,006 $165,586,345 $227,507,301 $733,532,652
Interest $25,497,597 $42,359,620 $121,513,641 $136,305,066 $198,745,472 $752,572,154
Abated ($57,897,841) ($69,743,692) ($281,809,666) ($399,235,354) ($749,409,440) ($7,298,653,359)
IRS Collectibility Curve
TABLE A-3. TDA Modules, Balances Due, Dollars Collected by Subsequent Payments and Offsets, Assessed Penalties, Assessed
Interest, and Abatements by Source of Assessment
Calendar
Year
Description
Self-Reported
Assessments
Substitute for Return Audit Assessments AUR Assessments
Trust Fund Recovery
Penalties
2003
TDA Count 76,305 127,153 248,863 1,115,474 110,324
Initial Balance Due $2,755,702,547 $1,641,819,169 $955,455,897 $5,935,437,250 $1,636,660,799
Subsequent Payments ($397,863,606) ($381,301,366) ($317,247,600) ($3,352,551,156) ($267,458,821)
Offset ($109,821,313) ($198,452,772) ($323,382,148) ($1,076,177,894) ($103,027,521)
Penalty $57,352,147 $104,629,310 $87,347,519 $594,619,903 $34,505
Interest $66,142,201 $72,386,963 $65,165,077 $542,889,882 $115,653,487
Abated ($1,347,079,999) ($245,313,974) ($145,199,035) ($362,429,282) ($638,341,982)
2004
TDA Count 148,322 130,994 256,753 1,028,470 114,071
Initial Balance Due $5,064,578,631 $1,790,767,383 $1,096,964,103 $5,585,456,769 $1,767,559,350
Subsequent Payments ($784,223,463) ($474,730,184) ($366,381,883) ($3,505,764,852) ($289,675,909)
Offset ($229,042,168) ($220,626,090) ($395,625,962) ($1,055,677,394) ($106,505,103)
Penalty $126,340,535 $120,222,356 $95,416,239 $556,173,822 $29,803
Interest $453,442,683 $182,694,977 $108,691,313 $728,528,130 $296,995,659
Abated ($2,340,659,814) ($231,996,225) ($232,552,410) ($380,021,768) ($767,861,296)
2005
TDA Count 512,705 224,899 301,903 1,104,554 101,588
Initial Balance Due $13,362,507,090 $2,034,842,462 $1,347,565,321 $5,544,297,832 $1,500,995,601
Subsequent Payments ($1,719,278,819) ($563,315,839) ($423,463,099) ($3,328,886,959) ($248,869,759)
Offset ($682,672,073) ($398,246,119) ($431,513,171) ($1,096,714,008) ($94,913,229)
Penalty $372,356,726 $150,049,224 $102,910,162 $534,072,724 $45,906
Interest $1,754,673,244 $272,574,120 $140,684,401 $901,732,852 $294,428,237
Abated ($6,251,321,458) ($240,489,498) ($384,254,445) ($338,857,989) ($604,296,121)
Beers, Hatch, Saldana, and Wilson
TABLE A-3. TDA Modules, Balances Due, Dollars Collected by Subsequent Payments and Offsets, Assessed Penalties, Assessed
Interest, and Abatements by Source of Assessment—Continued
Calendar
Year
Description
Self-Reported
Assessments
Substitute for Return Audit Assessments AUR Assessments
Trust Fund Recovery
Penalties
2006
TDA Count 588,943 273,576 374,373 1,214,361 102,374
Initial Balance Due $15,272,022,052.9 $2,699,929,404.0 $1,546,702,949.2 $6,662,831,209.9 $1,555,671,271.1
Subsequent Payments ($1,657,436,219.2) ($708,090,013.6) ($483,120,497.2) ($3,904,703,877.4) ($220,079,883.5)
Offset ($798,615,902.5) ($568,757,077.8) ($559,941,489.1) ($1,279,736,554.8) ($96,242,450.3)
Penalty $313,100,522.7 $185,710,811.0 $110,596,640.4 $616,339,300.9 $35,150.0
Interest $2,000,147,374.8 $396,544,510.4 $161,928,187.0 $1,022,051,805.4 $282,864,102.1
Abated ($6,571,418,753.8) ($368,654,726.7) ($396,185,415.2) ($576,039,465.8) ($641,631,939.2)
2007
TDA Count 1,043,966 328,809 491,988 1,330,059 104,034
Initial Balance Due $24,497,035,199.50 $2,852,164,654.01 $1,874,553,318.62 $7,150,372,177.98 $1,471,575,406.52
Subsequent Payments ($2,406,444,052.86) ($674,618,290.74) ($476,662,500.63) ($3,656,970,935.55) ($173,447,577.30)
Offset ($1,135,157,789.35) ($718,330,580.74) ($679,509,112.51) ($1,396,911,300.99) ($92,287,027.64)
Penalty $559,551,263.81 $219,753,090.56 $127,434,963.11 $679,524,580.41 $36,854.73
Interest $2,693,063,064.29 $396,338,868.59 $163,748,874.45 $1,008,328,975.43 $226,404,885.33
Abated ($10,482,352,227.22) ($397,787,490.46) ($532,432,329.44) ($826,537,704.52) ($509,468,588.88)
2008
TDA Count 739,496 311,267 544,576 1,408,584 126,674
Initial Balance Due $17,215,158,029 $3,275,957,777 $2,464,789,305 $8,573,658,078 $1,692,197,368
Subsequent Payments ($1,549,671,652) ($746,128,193) ($554,527,916) ($3,927,091,666) ($171,233,155)
Offset ($730,838,818) ($665,223,976) ($827,850,704) ($1,589,699,028) ($103,947,144)
Penalty $337,635,916 $238,267,045 $159,606,831 $821,717,247 $35,763
Interest $1,439,847,831 $332,816,518 $163,867,639 $955,104,268 $203,199,971
Abated ($6,728,095,595) ($525,851,177) ($747,290,401) ($994,646,932) ($524,877,644)
IRS Collectibility Curve
TABLE A-3. TDA Modules, Balances Due, Dollars Collected by Subsequent Payments and Offsets, Assessed
Penalties, Assessed Interest, and Abatements by Source of Assessment—Continued
Calendar
Year
Description
Self-Reported
Assessments
Substitute for Return Audit Assessments AUR Assessments
Trust Fund Recovery
Penalties
2009
TDA Count 1,059,119 328,596 421,222 1,258,574 133,484
Initial Balance Due $21,519,252,921 $3,510,915,440 $2,190,381,922 $9,287,978,110 $1,791,857,278
Subsequent Payments ($1,937,916,493) ($734,096,173) ($527,178,242) ($4,164,607,080) ($166,332,122)
Offset ($891,601,842) ($695,800,264) ($614,982,034) ($1,417,235,663) ($107,247,687)
Penalty $573,265,383 $267,037,832 $135,425,080 $878,486,072 $33,808
Interest $1,515,924,103 $301,249,911 $118,011,988 $803,810,795 $172,133,849
Abated ($7,729,519,040) ($449,702,771) ($599,496,724) ($822,895,861) ($496,312,590)
2010
TDA Count 786,668 341,242 696,468 1,615,298 165,008
Initial Balance Due $21,846,637,985 $3,745,192,392 $3,213,707,429 $10,254,615,336 $2,202,121,920
Subsequent Payments ($1,264,503,773) ($663,033,824) ($672,146,619) ($4,465,936,541) ($191,300,255)
Offset ($577,674,767) ($599,513,270) ($879,157,918) ($1,546,383,735) ($123,339,260)
Penalty $450,454,430 $295,161,887 $191,439,933 $896,627,625 $39,977
Interest $1,041,306,173 $234,136,935 $130,949,018 $694,263,873 $150,003,036
Abated ($8,523,041,119) ($762,864,033) ($896,730,683) ($1,006,484,824) ($684,970,705)
2011
TDA Count 769,554 320,692 703,735 1,473,234 206,428
Initial Balance Due $19,860,173,613 $3,860,505,398 $2,467,419,131 $9,734,400,489 $2,510,939,801
Subsequent Payments ($1,301,107,710) ($560,341,761) ($518,971,847) ($3,893,835,651) ($194,376,899)
Offset ($532,457,391) ($545,391,380) ($766,601,880) ($1,198,087,537) ($124,133,401)
Penalty $403,543,321 $214,594,684 $138,486,517 $734,750,156 $38,980
Interest $659,627,735 $159,112,330 $89,564,038 $509,380,819 $127,747,972
Abated ($7,927,276,034) ($740,644,539) ($435,026,997) ($1,534,273,270) ($731,930,494)
Beers, Hatch, Saldana, and Wilson
Table A-3. TDA Modules, Balances Due, Dollars Collected by Subsequent Payments and Offsets, Assessed Penalties,
Assessed Interest, and Abatements by Source of Assessment—Continued
Calendar
Year
Description
Self-Reported
Assessments
Substitute for Return Audit Assessments AUR Assessments
Trust Fund Recovery
Penalties
2012
TDA Count 530,422 346,807 667,103 1,601,048 217,242
Initial Bal. Due $15,981,125,775 $4,232,164,705 $2,991,886,015 $10,224,391,491 $2,483,987,382
Sub. Payment ($799,485,420) ($563,383,176) ($443,036,348) ($3,554,387,916) ($166,863,415)
Offset ($344,985,849) ($507,554,114) ($752,560,887) ($1,052,606,719) ($105,149,706)
Penalty $286,208,504 $212,280,910 $126,427,212 $623,128,493 $39,077
Interest $417,592,869 $147,703,005 $66,177,617 $405,922,275 $85,004,578
Abated ($5,860,055,257) ($341,658,757) ($681,903,277) ($635,580,165) ($679,545,902)
IRS Collectibility Curve
TABLE A-4. Initial TDA Balance, Subsequent Payments, Offsets, and Abatements by Collection
Channel*
ACS
Calendar
Year
Initial Balance Due Subsequent Payments Offsets Abated
2003 $7,792,592,325 ($3,426,144,186) ($1,700,612,873) ($1,101,444,823)
2004 $8,055,134,988 ($3,751,122,687) ($1,821,135,021) ($1,374,908,979)
2005 $10,998,087,606 ($4,449,976,986) ($2,306,307,552) ($2,323,868,875)
2006 $11,745,756,134 ($4,958,995,889) ($2,669,338,955) ($2,231,454,323)
2007 $13,328,119,659 ($5,152,715,921) ($3,313,012,446) ($2,498,865,753)
2008 $13,076,613,620 ($4,952,000,018) ($3,342,342,605) ($2,005,516,405)
2009 $20,164,274,356 ($6,033,827,223) ($3,225,236,763) ($4,106,056,899)
2010 $23,890,067,756 ($6,504,108,404) ($3,601,310,254) ($4,345,387,578)
2011 $20,559,657,101 ($5,362,106,864) ($3,035,428,058) ($3,362,113,103)
2012 $15,766,253,590 ($3,680,718,002) ($2,554,868,769) ($1,949,706,639)
Queue
Calendar
Year
Initial Balance Due Subsequent Payments Offsets Abated
2003 $4,456,531,893 ($1,302,443,755) ($274,152,689) ($1,025,099,018)
2004 $5,251,622,031 ($1,413,913,762) ($303,798,101) ($1,356,746,265)
2005 $7,259,341,395 ($1,236,407,732) ($339,609,532) ($2,698,940,436)
2006 $10,364,534,372 ($1,705,896,251) ($569,806,186) ($3,872,105,194)
2007 $13,356,607,079 ($1,474,213,610) ($514,373,032) ($4,802,778,031)
2008 $11,887,839,882 ($1,544,260,843) ($558,938,774) ($3,713,488,466)
2009 $9,028,536,600 ($853,994,321) ($364,974,713) ($2,467,988,439)
2010 $14,770,625,847 ($1,165,220,750) ($443,402,944) ($5,340,619,441)
2011 $15,017,679,946 ($1,167,520,082) ($382,384,896) ($5,536,502,040)
2012 $16,502,893,644 ($1,501,522,558) ($413,388,933) ($4,112,045,801)
CFf
Calendar Year Initial Balance Due Subsequent Payments Offsets Abated
2003 $3,077,066,975 ($972,658,039) ($175,980,683) ($859,433,429)
2004 $4,169,294,696 ($1,295,961,250) ($229,607,183) ($1,418,349,748)
2005 $7,738,655,844 ($1,627,873,501) ($440,612,413) ($3,043,952,030)
2006 $8,241,446,047 ($1,399,099,392) ($507,015,387) ($2,841,157,792)
2007 $13,993,724,570 ($1,811,016,272) ($666,115,209) ($5,784,459,696)
2008 $11,518,740,081 ($1,546,527,842) ($511,963,009) ($4,220,481,526)
2009 $12,794,889,563 ($1,710,656,216) ($583,342,161) ($4,142,578,147)
2010 $7,043,698,585 ($791,536,359) ($195,298,160) ($2,806,484,614)
2011 $7,348,880,870 ($905,494,742) ($165,359,102) ($3,092,255,382)
2012 $8,302,636,681 ($1,108,677,954) ($154,113,170) ($2,794,996,912)
*NOTE: The IRS is required by law to write off any remaining balance due at the expiration of the collection statute of limitations period (generally 10 years from the date of liability
assessment, but this period may be extended for several reasons, including bankruptcy).
Beers, Hatch, Saldana, and Wilson
TABLE A-5. Initial TDA Balance, Subsequent Payments, Offsets, and Abatements by Collection
Channel After Six Years*
ACS
Calendar
Year
Initial Balance Due Subsequent Payments Offsets Abated
2003 $7,792,592,325 ($3,073,090,254) ($1,462,600,955) ($1,027,367,242)
2004 $8,055,134,988 ($3,401,366,362) ($1,591,054,713) ($1,298,468,755)
2005 $10,998,087,606 ($4,033,340,814) ($2,034,143,955) ($2,201,007,908)
2006 $11,745,756,134 ($4,582,308,923) ($2,433,892,394) ($2,123,881,197)
2007 $13,328,119,659 ($4,848,687,675) ($3,125,283,670) ($2,413,837,112)
2008 $13,076,613,620 ($4,814,247,019) ($3,277,483,164) ($1,979,716,054)
2009 $20,164,274,356 ($6,032,295,430) ($3,223,772,255) ($4,105,339,235)
2010 $23,890,067,756 ($6,504,108,404) ($3,601,310,254) ($4,345,387,578)
2011 $20,559,657,101 ($5,362,106,864) ($3,035,428,058) ($3,362,113,103)
2012 $15,766,253,590 ($3,680,718,002) ($2,554,868,769) ($1,949,706,639)
Queue
Calendar
Year
Initial Balance Due Subsequent Payments Offsets Abated
2003 $4,456,531,893 ($1,133,286,932) ($221,764,929) ($947,606,322)
2004 $5,251,622,031 ($1,227,076,427) ($246,025,904) ($1,261,716,412)
2005 $7,259,341,395 ($1,030,055,031) ($271,314,994) ($2,534,957,190)
2006 $10,364,534,372 ($1,505,558,020) ($492,056,484) ($3,568,299,367)
2007 $13,356,607,079 ($1,291,060,172) ($456,578,391) ($4,566,614,755)
2008 $11,887,839,882 ($1,472,606,814) ($537,914,978) ($3,625,718,411)
2009 $9,028,536,600 ($853,546,234) ($364,865,502) ($2,467,952,050)
2010 $14,770,625,847 ($1,165,220,750) ($443,402,944) ($5,340,619,441)
2011 $15,017,679,946 ($1,167,520,082) ($382,384,896) ($5,536,502,040)
2012 $16,502,893,644 ($1,501,522,558) ($413,388,933) ($4,112,045,801)
CFf
Calendar
Year
Initial Balance Due Subsequent Payments Offsets Abated
2003 $3,077,066,975 ($867,563,109) ($144,855,544) ($803,396,569)
2004 $4,169,294,696 ($1,143,776,243) ($185,705,568) ($1,302,087,094)
2005 $7,738,655,844 ($1,375,997,735) ($347,979,258) ($2,849,242,920)
2006 $8,241,446,047 ($1,187,863,602) ($422,710,047) ($2,631,514,099)
2007 $13,993,724,570 ($1,600,475,227) ($589,298,287) ($5,453,310,168)
2008 $11,518,740,081 ($1,474,215,783) ($491,588,290) ($4,135,828,417)
2009 $12,794,889,563 ($1,709,354,805) ($583,054,052) ($4,142,180,675)
2010 $7,043,698,585 ($791,536,359) ($195,298,160) ($2,806,484,614)
2011 $7,348,880,870 ($905,494,742) ($165,359,102) ($3,092,255,382)
2012 $8,302,636,681 ($1,108,677,954) ($154,113,170) ($2,794,996,912)
*NOTE: The IRS is required by law to write off any remaining balance due at the expiration of the collection statute of limitations period (generally 10 years from the date of liability
assessment, but this period may be extended for several reasons, including bankruptcy).
