Indeed! Do you suppose that to be the ONLY cost imposed outside the tax itself?
What are the other costs? I've already estimated 9% direct costs for the employer's half of SS and Medicare plus corporate income tax on the profits. Now I'll add 2% (to be generous) for compliance costs. That still leaves 12% more (or about $1.2 trillion in total) to get to the point where embedded taxes and the NRST figures match so there is no net change in prices as FairTax.org claims.
Some of it is going to be in time and effort wasted in trying to avoid or defer income taxes. Also add some foolish investments promoted by the tax code. Some Senator likes Guatemalan fruit bats, so he puts a deduction in the tax code for investing in Guatemalan fruit bat farms and a lot of money gets wasted on those bats. Go to an NRST and you get rid of those stupid investments. Do those add up to the remaining 12%? Or do you have to count the employee's SS, Medicare and income taxes like Jorgenson said but FairTax.org claims you don't (because employees take home their entire paycheck)?