National Tax Journal, Vol. 41, no. 4, (December, 1988), pp. 579-81 CORPORATE TAX EVASION AND OUTPUT DECISIONS UNCERTAIN MONOPOLIST** OF THE LEONARD F. S. WANG* AND JOHN L. CONANT* 1. Introduction N their recent article, Kreutzer and Lee I (1986) explore the possibility of using a profit tax to reduce monopoly distortion. They conclude that monopolists can reduce their tax liability by overstating the costs of production, and that this cost overstatement (tax evasion) induces them to increase their output. Kreutzer and Lee's conclusion casts some doubt on the conventional view that profit taxes are neutral with respect to a monopolist's profit maximizing rate of output. Marrelli (1984) on the other hand, analyzed a monopolistic firm's decision on whether, and to what extent to avoid an ad valorem (sales) tax by under-reporting revenues. A considerable literature has followed the pathbreaking paper by Allingham and Sandmo (1972) focusing on the phenomenon of individual income tax evasion. Allingham and Sandmo pioneered the analysis by placing the taxpayer's decision concerning the level of declared income in a standard choice under uncertainty model. In these models, individual taxpayers analyze at the margin their expected benefits from undetected tax evasion and their expected costs from the penalty that accompanies a detected evasion. The purpose of this paper is to formulate an uncertainty model for monopolists along the lines of Allingham and Sandmo which incorporates the incentives to reduce tax liability by under-reporting prof_ its through an overstatement of production costs. This model will invalidate the conclusion reached by Kreutzer and Lee, and reinforce the generally held view that profit taxes are neutral with respect to the profit maximizing rate of output. The problem we consider here is important since a monopolist has the incentive to conceal the true cost of production when *Indiana State University, Terre Haute, IN 47809. 579 the average cost is declining evant range of output. over the rel- II. The Basic Model and Analysis We adopt the standard approach of analyzing decision making under uncertainty. The monopolistic firm can evade profit tax liability by cost overstatements (8), which are either detected (with probability p), or remain undiscovered (with probability 1 p). The firm's after-tax profit when the tax authority does not detect the cost overstatement is HI, and the after-tax and after-penalty profit when the authority successfully detects the evasion is F[2. Being detected in under-reporting of profits involves a penalty (s). It is assumed that this penalty increases the tax rate (t), so that the penalty tax rate is st (s > 1) which is applied by the tax authority to the unreported portion of actual profit. The firm's net profit when it overstates its costs and is not detected by the authorities is: Fli [R(Q) - C(Q)j t[R(Q) (I + 6)C(Q)l (1 t)[R(Q) C(Q)l + tbC(Q) (1) where R(Q) is total revenue and C(Q) is total cost. On the other hand, if the firm's cost overstatement is discovered by the taxing authorities, its net profit is: F12 III St[8c(Q)l (2) It is assumed that the preference function of the monopolist is given by a von Neuman-Morgenstem utility function, i.e., dU(Fl)/dFl > 0, U"(FI) U(fl)2U(II) with u,(n) /dF12 < 0. Here, U"(rI) < 0 imd plies that the monopolist is risk averse in the sense of Tobin. In our model there is a fixed probability (p) of tax evasion being discovered, and the firm is assumed to determine its optimal output level (Q) and National Tax Journal, Vol. 41, no. 4, (December, 1988), pp. 579-81 NATIONAL 580 TAX JOURNAL [Vol. XLI their result that the after-tax profit maximizing output will be larger than the output which would maximize profits in the absence of a tax. Their model, how(3) ever, did not recognize the probability that MAX EU - (I - P)U(rll) + PU(112) Q b the cost overstatement would be detected by the tax authorities who would then The first-order conditions for an interior impose a penalty on the amount of unmaximum of (3) can then be written as: reported profit (i.e., p = 0). With p = 0, as long as both t and 8 are positive, the marginal pre-tax profit, R' aEU (I p)[(R' C')(1 t) C' will be negative. And as a result,. the -aQ after-tax profit maximizing output, Q, is + t8c,]U'(Fil) + p[(RI - Cl)(i - t) greater than the output, Q which would (4) maximize profit in the absence of a tax.' + (I - S)tbC']U'(112) - 0 From (6a) and (6b) it is clear that the optimal output of the uncertain monopoand list, Q*, lies between Q and From (4) we have: aEu - (i - p)[tC(Q)]U'(fll) a8 U'(F12) (5) + P[(l - S)tC(Q)]U'(rl2) - 0 cost overstatement factor (b) so as to maxiniize its expected utility function EU ex ante; which can be written as: where R' is marginal revenue, C' is marginal cost, and U'(fli), U'(112) are the first derivatives of the utility function with respect to fl, and fl2, respectively. From (4) arid (5) we will be able to find the optimal values of Q and B. We assume that the second-order conditions are satisfied everywhere. Equation (4) can be written as: (i - p)[(R' - C')(1 t) + tbc,l U'(fll) P[(R' - C')(i - t) + (I - S)tbC']U'(fl2) (4') > 0, p), p, U'(fil) and U'(rl2) Since (1 equation (4') will be verified only if [(R' - C,)(1 t) + tbcll > 0 and [(R' - C')(1 - t) + s)tBCII < 0. That is, at the optimum, the firm will find its equilibriun, point somewhere between the quantities for which: (i - t)R' - [1 (1 + 8)t]C' p)[(R' P[(R' C')(1 + 6)t + sbt]C' t) + (I s)tBC'l And from (5) we have: (I - P) U'(F12) U'(Fll) p(l (8) S) From (7) and (8), we see that the choice of 8 considerably modifies the optimum condition for the firm's production decision. From (8) we find 8 - 6* and then equation (7) can be written as: U'(fl2) U,(rll) (1 p)[(R' - C')(1 - t) + tb*C'l p[(R' - C')(1 - t) + (1 s)ta*C'l (7') By equating the right and (8) we get: [1 C')(I - t) + tBC'l (7) (6a) and (1 - t)RI (I hand sides of (7') (6b) Condition (6a) is the same as Kreutzer and Lee's condition (2) which provided s(R' - C')(1 - t) - 0 (9) Since 0 - t :s 1 and s > 1, there exists National Tax Journal, Vol. 41, no. 4, (December, 1988), pp. 579-81 No. 41 THE UNCERTAIN a Q - Q such that R' - C'; that is, an uncertain monopolist who is able to find the optimal cost overstatement factor, and set its production level where marginal revenue equals marginal cost. This result is particularly interesting because it implies that neither the profit tax nor the penalty rate affect the firm's output decision whatsoever. In general, it can be said that if the profit-tax-paying firm is able to equate the marginal rate of substitution between rll (escape) and n2 (detected) to the real price of evasion, -(I - p)/p(l - s), then tax evasion (overstating costs) has no influence on the output decision of the uncertain monopolist. That is, the production decision and the evasion decision are, in this case, separable. This result significantly differs from the certainty model of Kreutzer and Lee which does not consider the probability of detection and punishment where the monopolist increases production beyond the point where marginal cost equals marginal revenue. In their model the firm increases output until the marginal loss of production is equal to the marginal gain from reduced tax liability on overstated costs. An uncertain monopolist in our model sets the level of production at the traditional optimum (MR - MC), and then considers the tax rate, penalty rate, and the probability of detection in determining the optimal level of cheating which maximizes its expected utility of after-tax profits. The well-known result that profit taxes are neutral under certainty also holds under an uncertainty framework, and thus profit taxes cannot be used by public policy analysts to reduce monopoly distortion. A comparative statics analysis of the model reveals that increases in the profit tax rate, the penalty rate and/or the probability of detection reduce the optimal level of profit tax evasion.2 III. Conclusion We have examined the profit tax evasion and output decisions of the uncertain 581 MONOPOLIST monopolist. We have shown that contrary to the results of Kreutzer and Lee, that when the firm considers the probability of detection and punishment in its expected utility function of profit, that the uncertain monopolist's optimal rate of output is not affected by either the profit tax or the penalty rate. The firm's decisions concerning the level of output and the extent of tax evasion are separable. Although not derived here, a comparative static analysis of our model shows that variations in the tax rate, the penalty rate, and the probability of detection affect the level of tax evasion. As in the literature on individual income taxes, increases in these parameters reduce the optimal amount of tax evasion. ENDNOTES **We wish to thank two anonymous referees for their helpful suggestions. 'If we ignore the strategy of over-reporting costs (b 0), FI, and fl2 are identical, and thus U(Hl) = U(F12) and equation (4') reduces to: U'(H)[(R' C')(1 t)] 0 Thus, in the absence of tax evasion the equilibrium output level will be found where MR MC, yielding the familiar result that a profit tax is neutral. 'The comparative statics analysis is available from the authors on request. REFERENCES Allingham, M. G. and A. Sandmo, "Income Tax Eva sion: A Theoretical Analysis," Journal of Public Economics 1 (1972), 323-338. Becker, G. S, "Crime and Punishment: An Economic Approach," Journal of Political Economy 76 (1968), 169-217 Cowell, F. A., 'The Economic Analysis of Tax Evasion" in Surveys in the Economws of Uncertainty, eds. John D. Hey and P. J Lambert, New York: Basil Blackwell Inc., 1987, 173-203. Hey, J. D., Uncertainty in Microeconomics, Oxford: Martin Robertson, 1979. Kreutzer, D and D. R. Lee, "On Taxation and Un derstated Monopoly Profits," National Tax Journal 39 (1986), 241-243 Marrelli, M., "On Indirect Tax Evasion," Journal of Public Economics 25 (1984), 181-196. Paulsen, J W. and R. D. Adams, "Optimal Taxation of a Monopoly," National Tax Journal 40 (1987), 121-125. Sandmo, A, "On the Theory of the Competitive Finn under Price Uncertainty," American Economic Re view 61 (1971), 65 73.
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