Yeah, it’s an imperfect first-stab calculation at best. But that doesn’t mean that 1 in 12,000 is necessarily an underestimate because while the 8,143,000 denominator may be exaggerated for the reasons you suggest; the 699 numerator is too, for the reason I gave (“even if every one of those prosecutions had been of people who merely refused to pay”). In fact, few to none of those 699 prosecutions were of people who merely refused to pay. An appendix to their report shows how many indictments the IRS pursued in a variety of categories (this adds up to more than 699 because some non-tax crimes e.g. narcotics, money laundering are also prosecuted via the same unit). Non-payment doesn’t even make the list:
Abusive Tax Schemes: 35
Corporate Tax Fraud: 23
Financial Institution Fraud: 20
Bank Secrecy Act: 338
Employment Tax: 142
Healthcare Fraud: 69
Abusive Return Preparer Program: 112
Identity Theft: 88
Money Laundering: 701
International Operations: 143
Narcotics: 475
Non-Filer: 115
Public Corruption: 27
Questionable Refund Program: 51
Terrorism: 33
Thanks for the response. This goes far enough afield of my expertise that I don’t think I can give very helpful answers to your specific questions. I don’t have any experience with corporate tax refusal of this sort. In the very limited anecdotal reports I’ve seen, it seems like the IRS is most likely to crack the whip and potentially pursue corporate officers when 1) the corporate entity fails to pay employment taxes (payroll/social-security taxes) after withholding them from employees’ paychecks, 2) when there’s actual fraud/dishonest filing involved, 3) when there’s no filing of required forms; in roughly that order of severity. I’m much less confident in anticipating the IRS’s behavior here than I am in the case of individual tax-nonpayers.
As far as the 10-year limitations deadline, again here I have much less information to go on for corporate taxpayers than for individuals. I know in the case of individuals, once the tax debt passes the “collection statute expiration date” it just sort of vanishes from the system and so they stop bothering you about it.
Note that if the corporate entity formally files for bankruptcy that this suspends the ticking of the statute of limitations clock until six months after the bankruptcy is resolved.