United States General Accounting Office

GAO Testimony

Before the Committee on Ways and Means, House of

Representatives

For Release

on Delivery

Expected at

10:00 a.m. EDT

Thursday, May 8, 1997

TAX ADMINISTRATION

Earned Income Credit

Noncompliance

Statement of Lynda D. Willis, Director, Tax Policy and

Administration Issues, General Government Division

GAO/T-GGD-97-105

Statement 

Tax Administration: Earned Income Credit

Noncompliance

Mr. Chairman and Members of the Committee

We are pleased to be here today to participate in the Committee’s inquiry

into noncompliance surrounding the Earned Income Credit (EIC)—a

refundable tax credit available to low-income, working taxpayers. As used

in connection with the EIC, “noncompliance” occurs when persons either

claim credits to which they are not entitled or claim credits in excess of

the amount to which they are entitled. This statement is based on our past

work on the EIC,

1

 a review of limited data on the results of IRS’ study of EIC

filers for tax year 1994,2 and a review of various Department of the

Treasury proposals to reduce EIC errors.

Our statement makes the following points:

• EIC noncompliance has been a concern for a number of years and is a

major factor underlying our designation of filing fraud as one of the

federal program areas at high risk because of vulnerability to waste, fraud,

abuse, and mismanagement.3

 Through design changes and administrative

actions, noncompliance (expressed as a percentage of total EIC dollars

paid out) has been reduced since 1988 but, because of increases in the

number of claimants and changes in credit amounts over the past few

years, the amount of dollars erroneously paid out has increased

dramatically. A root cause of EIC noncompliance is the self-determination

of eligibility by taxpayers combined with IRS’ limited ability to verify

eligibility before the refund is issued.

• IRS has undertaken, with some success, a variety of efforts to reduce EIC

noncompliance in recent years. While the impact of IRS’ efforts cannot be

precisely quantified, it is reasonable to expect that recent declines in the

noncompliance rate were in part the result of IRS’ efforts. How much

further it can be reduced with available resources is uncertain.

• It will not be easy to significantly reduce EIC noncompliance because of

the nature of the credit and the design of IRS’ systems. Treasury has

announced eight proposals, six of which would involve legislation, to

reduce EIC noncompliance. Those proposals provide a starting point for

deliberations on what can reasonably be done to address this difficult

problem. Various questions need to be answered in assessing those

proposals, the most significant being whether they get at the real causes of

noncompliance.

1

A list of related GAO products is at the end of this testimony.

2

We did not assess IRS’ study methodology or the reliability of its reported results.

3

High-Risk Series: IRS Management (GAO/HR-97-8, Feb. 1997).

Page 1 GAO/T-GGD-97-105
Statement 

Tax Administration: Earned Income Credit

Noncompliance

Background Congress established the EIC in 1975 to (1) offset the impact of Social

Security taxes on low-income families and (2) encourage low-income

families to seek employment rather than welfare.

EIC eligibility depends on taxpayers’ amount of earned income4 or, in some

cases, adjusted gross income (AGI).5

 Credit amounts depend on the number

of qualifying children who meet age, relationship, and residency tests. The

credit gradually increases with increasing income (the phase-in range),

plateaus at a maximum amount (the plateau range), and then gradually

decreases until it reaches zero (the phase-out range). Taxpayers with

earned income or AGI exceeding the maximum qualifying income level are

not eligible for the credit. Taxpayers with AGI falling in the credit’s

phase-out range receive the lesser amount resulting from using their

earned income or AGI in calculating the credit.

EIC coverage and benefit rules have been modified several times since

1990. In the Omnibus Budget Reconciliation Act (OBRA) of 1990, Congress

made two major changes to the EIC that took effect in tax year 1991. These

changes (1) adjusted the credit structure to grant different credit amounts

to taxpayers with one qualifying child and taxpayers with two or more

qualifying children and (2) added two supplemental credits—one for

taxpayers with a child under 1 year of age and another for taxpayers who

paid health insurance premiums on policies covering their children. OBRA

1990 also allowed taxpayers with a filing status of single to claim the

credit, as long as they had a qualifying child, and specified a general

increase in credit rates that was to be phased-in over 4 years (the planned

increase for 1994, however, was superseded by 1993 legislation).

OBRA 1993 made two changes in the credit’s structure that went into effect

in tax year 1994. First, to simplify EIC filing, the act repealed the

supplemental young child and health insurance credits. Second, the act

expanded EIC eligibility to include certain taxpayers without qualifying

4

Earned income for calculating the EIC includes both taxable and nontaxable earned income. For the

EIC, taxable earned income includes (1) wages, salaries, and tips; (2) union strike benefits;

(3) long-term disability benefits received prior to minimum retirement age; and (4) net earnings from

self-employment. Nontaxable earned income includes (1) voluntary salary deferral such as 401(k)

plans or the federal thrift savings plan, (2) pay earned in a combat zone, (3) basic quarter and

subsistence allowances from the U.S. military, (4) housing allowances or rental value of a parsonage

for the clergy, and (5) excludable dependent care benefits.

5

In addition to taxpayers’ taxable earned income, AGI includes their taxable income from other

sources such as investments, alimony, and unemployment compensation. Beginning in tax year 1996,

taxpayers are to use a newly defined “modified AGI” that excludes certain losses to determine EIC

eligibility and to calculate the credit.

Page 2 GAO/T-GGD-97-105
Statement 

Tax Administration: Earned Income Credit

Noncompliance

children or “childless adults.”6 OBRA 1993 also increased, over a 3-year

period beginning in tax year 1994, the maximum credit for families with

children.

The maximum basic credit amount for EIC families with two or more

children was $953 in tax year 1990, $1,511 in tax year 1993 (reflecting OBRA

1990), and $3,556 in tax year 1996 (reflecting OBRA 1993). The maximum

credit for childless adults in tax year 1996 was $323.

The Personal Responsibility and Work Opportunity Reconciliation Act of

1996 made three additional changes to the EIC. First, beginning with tax

year 1996 returns, the act made taxpayers with certain investment income

greater than $2,200 ineligible for the EIC, regardless of their earned income

or AGI. Second, the act created a “modified AGI” to be used in calculating

the credit. Modified AGI disregards certain losses from investments and

businesses. And third, the act denied the EIC to filers without valid Social

Security Numbers (SSN).7

 Taxpayers were already required to provide valid

SSNs for qualifying children.

As shown in figure 1, both the number of taxpayers claiming the credit and

EIC program costs (in 1996 dollars) increased steadily from tax years 1990

through 1994. In large part, this growth reflects the impact of either

eligibility or benefit expansions implemented in tax years 1991 and 1994,

as discussed earlier.

6

Although referred to as “childless adults,” these taxpayers may be noncustodial parents or may live

with a child who, for some reason, cannot be claimed as an EIC qualifying child.

7

A valid SSN is one that matches Social Security Administration records.

Page 3 GAO/T-GGD-97-105
Statement 

Tax Administration: Earned Income Credit

Noncompliance

Figure 1: EIC Costs and Number of

Claims, Tax Years 1990 Through 1994

1990 1991 1992 1993 1994

0

10

20

30

40

50

0

5

10

15

20

25

Claims (millions) Costs (1996 dollars in billions)

9

22

12

19

25

20

15

10

5

0

Tax year

EIC costs in constant 1996 dollars

Number of taxpayers claiming EIC

21

15

 Families 

with 

qualifying 

children

Total

Total

Families 

with 

qualifying 

children

Source: GAO analysis of IRS Statistics of Income data.

EIC Noncompliance

and IRS’ Efforts to

Control It

Despite efforts over time to change design and administration of the EIC, it

is still a major source of noncompliance. That continuing noncompliance

is one reason why refund fraud remains on our list of high-risk federal

program areas.

IRS’ study of tax year 1994 EIC filers showed that of $17.2 billion in EIC

claimed, 25.8 percent ($4.4 billion) was overclaimed. While that

percentage of noncompliance is an improvement over the level identified

in the 1988 Taxpayer Compliance Measurement Program (TCMP), the

dollars involved have increased significantly.8

 The 1988 TCMP showed that

8

Before IRS’ study of tax year 1994 EIC filers, the 1988 TCMP provided the most current

comprehensive data on EIC noncompliance. IRS did a study of tax year 1993 EIC filers, but that study

only covered returns filed electronically during the last 2 weeks of January 1994.

Page 4 GAO/T-GGD-97-105
Statement 

Tax Administration: Earned Income Credit

Noncompliance

about $1.9 billion, or 34 percent of the total EIC paid out, was awarded

erroneously.

The lower rate of noncompliance since 1988 may be due, at least in part, to

legislative changes since the 1988 TCMP. In that regard, IRS data indicated

that taxpayers who claimed the wrong filing status were the most frequent

source of EIC error in the 1988 TCMP. Legislative action in 1990 simplified

the rules for qualifying for the credit by eliminating different eligibility

rules for different filing statuses. Even with that change, eligibility-related

compliance issues remain. For claimants of the credit for families with

children, eligibility for the credit is still self-determined by the taxpayer

using a three-part test based on the relationship of the child to the

taxpayer, the length of time the child lived with the taxpayer, and the

child’s age.

Congress has long been concerned about the high level of EIC

noncompliance. However, reducing it to more acceptable levels will be

difficult. Many of the noncompliance problems identified by IRS are the

result of a process whereby taxpayers self-determine their eligibility for

the credit and/or the amount of credit they are due. These erroneous

claims frequently related to qualifying children or choosing the wrong

filing status.9

 In both instances, IRS faces difficulty in verifying the

information on the return without using field resources to determine

taxpayer eligibility in a fashion similar to that used by organizations

administering welfare programs.

The reported level of EIC noncompliance is much higher than the reported

level of noncompliance in some other federal outlay programs but those

other programs also have much higher administrative costs. For example,

according to the Committee on Ways and Means 1996 Green Book, about

6.1 percent of the dollars paid out under the Aid to Families With

Dependent Children (AFDC) program was overpaid in fiscal year 1993 and

7.3 percent of the dollars paid out in the Food Stamp program was

overpaid in fiscal year 1995. As we noted in June 1995 testimony before the

Senate Finance Committee, those programs not only have lower

noncompliance rates than the EIC program but also have administrative

9

A change in filing status, per se, will not necessarily disqualify a taxpayer from claiming the EIC. Only

taxpayers who use the married-filing-separately status are ineligible for the credit. However, reporting

an incorrect filing status has implications for correctly reporting income. For example, taxpayers who

file as a head of household when they should have filed as married may underreport income, by

excluding their spouse’s income, and thus overclaim, in whole or in part, the EIC.

Page 5 GAO/T-GGD-97-105
Statement 

Tax Administration: Earned Income Credit

Noncompliance

costs that likely are many times higher than those of the EIC program.10

Data available at that time showed AFDC and Food Stamp administrative

costs of about 12 percent of total program expenditures in 1993. In

comparison, we estimated EIC administrative costs to be about 1 percent of

EIC program costs.11

Causes of EIC

Noncompliance

Before deciding on how to reduce EIC noncompliance, it is important to

know the major causes of that noncompliance. Data IRS made available on

the results of its study shed little light on that question. According to an

analysis of IRS’ study by Treasury’s Office of Tax Analysis, however, the

three most common causes were (1) taxpayers claiming qualifying

children who did not reside with them for over half the year, (2) taxpayers

claiming the wrong filing status, and (3) complicated living arrangements

involving more than one custodial caregiver.

It seems clear that a major share of the problem can be traced back to the

nature of the credit, as explained by an IRS consultant in 1993. According

to the consultant, the EIC, and other tax credits, have historically caused

problems for IRS because IRS’ systems were designed and, for the most

part, are operated with the overriding objective of enabling anyone who

wants to pay their taxes to do it. The distribution of EIC is philosophically

different from the issuance of traditional refunds, where the government

returns the taxpayer’s own money after excess withholding. The

consultant noted that payment of the EIC has much more in common with

government distribution of welfare benefits through other agencies but

that the standards of proof required to prove eligibility for EIC are not

comparable to the standards of proof required for receipt of welfare

benefits. As he pointed out, establishing eligibility for benefits delivered

through other agencies normally requires the claimant to deal with

government employees face to face; to produce proof of identification; and

to prove the existence of, and relationship with, any relevant dependents.

These types of controls are foreign to traditional IRS modes of operation.

A Treasury Task Force on Tax Refund Fraud made similar observations in

1994. According to the Task Force, (1) every refundable credit provides

some incentive for the filing of problematic returns, and the incentive rises

as the amount of the refundable credit rises and (2) the incentive to file

problematic returns is likely to increase as IRS’ capability to verify

10Earned Income Credit: Noncompliance and Potential Eligibility Revisions (GAO/T-GGD-95-179,

June 8, 1995).

11This estimate is for return and refund processing costs only and does not include the cost of IRS

enforcement efforts related to EIC noncompliance.

Page 6 GAO/T-GGD-97-105
Statement 

Tax Administration: Earned Income Credit

Noncompliance

information on the return decreases. With the EIC, there are various

important pieces of information, such as filing status and the existence of

qualifying children, that IRS cannot easily verify. The relationship between

verifiable information and compliance is not unique to the EIC. Throughout

the tax system, noncompliance tends to be higher whenever there is an

absence of easily verifiable data.

IRS Efforts to Control EIC

Noncompliance

IRS took several steps in the past few years to combat EIC noncompliance,

with some success. Although the impact of IRS’ efforts cannot be precisely

quantified, it is reasonable to assume that those efforts contributed to the

recent decline in the rate of EIC noncompliance.

Improved verification of SSNs was a key objective of IRS’ recent efforts. For

electronic returns, IRS increased the number of automated filters that are

designed to identify and reject submissions that involve missing, invalid,

or duplicate SSNs. Through those filters, IRS identified 4.1 million SSN

problems on tax year 1994 returns, 1.3 million of which involved the EIC.

This year, as of April 24, the filters identified about 3.2 million SSN

problems, of which 1.1 million involved the EIC.

IRS also emphasized SSN verification on paper returns. For tax year 1994, it

identified 3.3 million paper returns with missing or invalid SSNs (how many

involved EIC returns is unknown) and followed up on 1 million of those

cases (it did not have sufficient resources to follow up on all 3.3 million).

IRS continued that effort, but at a reduced level, for tax year 1995 paper

returns. According to IRS, these verification efforts resulted in

recommended changes to taxpayers’ refunds or tax liabilities of about

$900 million in fiscal year 1996. Starting with tax year 1996 returns filed

this year, IRS was authorized to treat missing or invalid SSNs on filed

returns as math errors. As such, IRS can automatically reduce or deny the

taxpayer’s EIC claim, if there is any.

Also for tax year 1994, IRS (1) improved the Questionable Refund Program,

(2) strengthened the process for checking the suitability of persons

applying to participate in the electronic filing program

as return preparers or transmitters, and (3) eliminated the direct deposit

indicator.12

12The direct deposit indicator gave return preparers a quick signal from IRS that a taxpayer was going

to receive a refund check and was relied on by providers of Refund Anticipation Loans. IRS’ objective

in eliminating the indicator was to give providers of Refund Anticipation Loans greater incentive to

check the eligibility of EIC claimants before approving the loans.

Page 7 GAO/T-GGD-97-105
Statement 

Tax Administration: Earned Income Credit

Noncompliance

Despite the various changes discussed above, IRS’ study of tax year 1994

EIC filers indicates that much more needs to be done. For example, even

with the many electronic filing filters, which are intended to keep

erroneous returns from being submitted electronically, the percent of tax

year 1994 electronic returns with EIC overclaims, according to IRS’ data,

was almost as high as the percent of paper returns (25.3 compared with

26.1). Also, IRS determined that even if its study results were adjusted to

reflect the impact of its enforcement efforts in 1995 and the new

math-error procedure being used this year, the overall noncompliance rate

would still be about 21 percent.

It is also interesting to note, as shown in table 1, that the number of

fraudulent returns detected by the Questionable Refund Program has

declined since 1994, with a dramatic decrease in 1996.

Table 1: Questionable Refund Program

Data for 1993 Through 1996

Calendar year

Number of

fraudulent returns

detected

Amount of

fraudulent dollars

detected (in

millions)

Percent of

fraudulent returns

that involved the

EIC

1993 77,840 $136.8 98

1994 77,781 160.5 91

1995 62,309 131.7 73

1996 24,919 82.5 72

Source: IRS data.

According to program officials, a major reason for the decline in

fraudulent returns and dollars detected in 1996 was a staffing reduction

from 553 full-time equivalent staff in 1995 to 379 full-time equivalent staff

in 1996.

What More Can Be

Done?

It will not be easy to significantly reduce EIC noncompliance without

somehow addressing the basic underlying problem—the

self-determination of eligibility by taxpayers and IRS’ limited ability to

verify that eligibility before issuing the refunds. On April 23, 1997, Treasury

announced eight proposals, six of which would require legislation, that it

believes will help reduce noncompliance.

The six proposals requiring legislation would (1) deny future EIC claims

from persons who are found to have claimed the EIC fraudulently or

through reckless or intentional disregard of the rules and regulations;

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Tax Administration: Earned Income Credit

Noncompliance

(2) require taxpayers who have had an EIC claim denied after an audit to

prove their eligibility to IRS before being allowed future credits; (3) allow

IRS to place liens and execute levies on a portion of unemployment

compensation, welfare benefits, and other types of assistance in order to

recapture EIC claims that were found to be erroneous after IRS had paid

them; (4) penalize preparers who did not meet certain due diligence

requirements; (5) clarify the definition of a foster child; and (6) conduct

state tests of new ways to provide the EIC and to verify eligibility. The

other two proposals would (1) increase IRS’ enforcement efforts and

(2) expand access to volunteer return preparation services.

There are not enough details in IRS’ study and Treasury’s announcement to

identify the major causes of EIC noncompliance or to assess the costs,

benefits, and administrability of Treasury’s proposals. However, based on

available information as well as our past work on the EIC specifically and

tax administration in general, we have identified several issues that

Congress needs to consider in deliberating on those proposals.

The most important issue is whether the various proposals get at the real

causes of noncompliance. According to IRS’ data, for example, a

disproportionate segment of the noncompliant returns involved incorrect

filing status. However, IRS’ report provides no information that helps

explain what it is about those claims that made them noncompliant, and

none of Treasury’s proposals directly addresses that issue.

On the other hand, three Treasury proposals address issues that do not

seem, on their face, to be major causes of noncompliance. Those

proposals call for (1) clarifying the definition of a foster child; (2) testing

alternate ways to provide advance EIC payments and, at the same time, to

verify the eligibility of persons receiving the advance payments; and

(3) increasing the availability of volunteer return preparation assistance.

Although each of those actions probably has some merit, IRS’ report and

Treasury’s proposals provide no evidence that the benefits, in terms of

reducing EIC noncompliance, would be of any consequence.

Specifically,

• IRS’ report provides no information on the extent to which noncompliance

can be traced back to confusion over the definition of a foster child or

even how many EIC claims involve foster children,

• only about 1 percent of all EIC recipients have historically used the

advance payment option, and

Page 9 GAO/T-GGD-97-105
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Tax Administration: Earned Income Credit

Noncompliance

• IRS has provided no data comparing the noncompliance rate for returns

done without the help of a preparer and those done by preparers, much

less volunteer preparers.

A second issue relates to administrability. Much more information is

needed on the proposals and how they will be implemented in order to

determine if they can be easily administered. The proposals that most need

attention in this regard, because they would apparently involve major

operating changes, are the ones that would (1) automatically deny the EIC

for several years to anyone who is found to have claimed the credit

fraudulently or due to reckless or intentional disregard of the rules and

regulations, (2) require taxpayers who had an EIC claim denied after an

audit to prove their eligibility for future credits, and (3) penalize preparers

who did not meet certain due diligence requirements.

To assess the administrability of the preparer penalty proposal, for

example, we would want to know what preparers would have to do to

demonstrate due diligence and what IRS would have to do enforce those

requirements. Our interest in this proposal is heightened by the results of

our past work on preparer penalties. In a 1991 report, we said that IRS’

examiners and supervisors were reluctant to pursue return preparer

penalties because of the low dollar amounts of the penalties.13 We wonder

whether the new penalties proposed by Treasury would be viewed

similarly.

In assessing administrability, it is also important that Congress consider

whether the action being proposed is the most appropriate given the facts.

In explaining its proposal that certain EIC claims be automatically denied,

for example, Treasury says that “existing civil penalties do not appear to

be an effective deterrent against ineligible taxpayers repeatedly claiming

the [EIC].” We saw nothing from IRS’ study related to the effectiveness of

penalties. Nor have we seen any information on the extent to which IRS, in

the past, has asserted available civil and criminal sanctions for fraudulent

or reckless EIC claims and the extent to which penalized parties have

submitted fraudulent claims afterwards. Such information would help

determine if the answer lies in better administering existing procedures or

establishing new procedures.

A third issue surrounding Treasury’s proposals involves the need to ensure

that any legislative or administrative change include adequate controls to

13Tax Administration: Effectiveness of IRS’ Return Preparer Penalty Program Is Questionable

(GAO/GGD-91-12, Jan. 7, 1991).

Page 10 GAO/T-GGD-97-105
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Tax Administration: Earned Income Credit

Noncompliance

protect taxpayer rights. For example, Treasury is proposing that IRS be

allowed to place liens and execute levies on a portion of unemployment

compensation, welfare benefits, and other types of assistance in order to

recapture EIC claims that were found to be erroneous after IRS had paid

them. Those types of income are now exempt from levy. It is for Congress

to decide whether there is now sufficient reason to revise those

exemptions. But, it is important in doing so that any such change include

adequate controls to protect taxpayers’ rights.

A final issue involves tradeoffs. It is important that concern about EIC

noncompliance not become so encompassing that other areas of

noncompliance are neglected. In that regard, one of Treasury’s proposals

calls for aggressive IRS action to prevent the payment of erroneous EIC

claims. While we support the first part of that proposal—the development

of new profiles to help IRS better target its enforcement efforts—we cannot

support the second part—earmarking substantial resources for an

intensified EIC compliance effort—without knowing the tradeoffs. IRS, like

most of the federal government, is facing stagnant or declining resources

through 2002. Consequently, knowing where the resources will come from

is critical. Equity and financial concerns have already been raised about

IRS reducing its audit coverage of high income individuals in order to target

EIC returns.

To assess tradeoffs, it is important to know what the return on investment

is for EIC-related enforcement efforts compared with other programs. In

fiscal year 1995, for example, all examinations done by tax auditors (those

IRS staff who would normally do EIC-related audits) resulted in average

additional recommended taxes of about $3,500 per return, compared to

the average EIC refund that year of less than $1,500.

Finally, as IRS becomes more and more involved in determining whether

taxpayers are eligible to receive the EIC, the benefits of delivering income

assistance to low income taxpayers through the tax code may erode.

Specifically, administrative costs will increase and participation rates may

fall. In addition, IRS employees will be faced with new job responsibilities

traditionally more related to welfare programs than tax administration.

In conclusion, Mr. Chairman, many questions remain about EIC

noncompliance and the most effective ways to reduce it. IRS efforts have

reduced the level of noncompliance but it still remains above 20 percent,

Page 11 GAO/T-GGD-97-105
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Noncompliance

with several billion dollars in overclaimed credits annually. How much

further it can be reduced with available resources is uncertain.

As I noted earlier, it will not be easy to significantly reduce EIC

noncompliance without somehow addressing the basic underlying

problem—the self-determination of eligibility by taxpayers and IRS’ limited

ability to verify that eligibility.

Treasury’s proposals provide a starting point for deliberations on what can

reasonably be done to address this difficult problem. Much more

information is needed on the proposals and IRS’ study findings before any

overall judgment can be made on how much the proposals will contribute

to reducing noncompliance.

It is important, in further deliberations on Treasury’s proposals or those

made by others, that Congress and the administration consider whether

(1) the actions being proposed are feasible; (2) potential benefits justify

expected costs, especially in light of tighter budgets and other compliance

problems facing IRS; and (3) adequate procedures are built in to protect

taxpayers’ rights.

That concludes my statement. We welcome any questions that you may

have.

Page 12 GAO/T-GGD-97-105
Page 13 GAO/T-GGD-97-105
Page 14 GAO/T-GGD-97-105
Page 15 GAO/T-GGD-97-105
Past GAO Products Relating to the EIC

Earned Income Credit: IRS’ 1995 Controls Stopped Some Noncompliance,

But Not Without Problems (GAO/GGD-96-172, Sept. 18, 1996)

Earned Income Credit: Profile of Tax Year 1994 Credit Recipients

(GAO/GGD-96-122BR, June 13, 1996).

Earned Income Credit: Noncompliance And Potential Eligibility Revisions

(GAO/T-GGD-95-179, June 8, 1995)

Earned Income Credit: Targeting to the Working Poor (GAO/T-GGD-95-136,

Apr. 4, 1995).

Earned Income Credit: Targeting to the Working Poor (GAO/GGD-95-122BR,

Mar. 31, 1995)

Tax Administration: Earned Income Credit—Data on Noncompliance and

Illegal Alien Recipients (GAO/GGD-95-27, Oct. 25, 1994).

Tax Policy: Earned Income Tax Credit: Design and Administration Could

Be Improved (GAO/GGD-93-145, Sept. 24, 1993).

Earned Income Tax Credit: Advance Payment Option Is Not Widely Known

or Understood by the Public (GAO/GGD-92-26, Feb. 19, 1992).

The New Earned Income Credit Form Is Complex and May Not Be Needed

(GAO/T-GGD-91-68, Sept. 17, 1991).

(268803) Page 16 GAO/T-GGD-97-105
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