The study only includes compliance and enforcement costs, not tax planning..billions are spent to understand the tax laws and apply them to one's advantage, not just to comply with them....Tax attorneys and tax accountants do just, interpret plan, and advise on tax laws, whereas compliance does not involve those things, only compilation. The law is full of loopholes and gotchas and it takes professional help to manuever through the minefield..without it you may be paying more than you need to. I'd like to know that 45 accountants come up with the same answer for one tax return than 45 different answers, and that does not even include planning..the system is broken and needs fixing...
NRST is not a miracle that solves all problems but it seems far better than anything else I have seem suggested. Do you believe our current system is fair and simple? Does the power lie with the people or Congress?
The Payne Study often referenced by many FairTax supporters lumps enforcement and avoidance (planning) together and values their total impact at about 1/3 of the value attributed to actual "compliance costs" (filing forms, record keeping and such.) That would suggest, using your study as a base for "compliance cost" for businesses at $91 Billion, that "planning" adds no more than $30 Billion, or so ... and that double counts enforcement (Payne lumps enforcement with planning, Slemrod lumps enforcement with compliance.)
That bring compliance, enforcement, and planning to no more than $121 Billion. Still far short of the FairTax claims.
Do have another source that would help pin down the actual magnitude of "planning costs?"