More Carrots, Fewer Sticks: Why Employers should be Offered in Payroll Tax and Executive Compensation Audits All the Protections of Rev. Proc. 64-22‪.‬

I. INTRODUCTION The principles of tax administration outlined by Commissioner Mortimer Caplin in Revenue Procedure 64-22 are as sound today as they were forty-five years ago, when both the Internal Revenue Code (Code) and the taxpaying populace were less than one-tenth their current size. (1) More particularly, the Code in 1964 was a single slender volume, and is two ponderous volumes today, printed with smaller type, thinner paper, and copious textual notes referencing the nearly 400 tax bills enacted since the Code was last recodified in 1954. (2) The numbers of taxpayers and return filers have grown exponentially as well, reflecting not only population growth, but also a dramatic expansion in the numbers and types of taxpaying entities and of tax and information returns. Despite this growth in the Code's complexity and in the numbers of affected taxpayers, Mr. Caplin's basic point holds true, that taxpayers will not continue to make the voluntary tax payments that are fundamental to our income tax system unless all federal tax administrators: