The AICPA said in its cover letter, "We believe the JCT proposals are fundamentally wrong in that any abuse with the current system is not related to the SECA/FICA tax base and therefore such tax base should not be expanded to combat the tax gap. The tax gap represents an underpayment by taxpayers who are not complying with existing law. The tax gap is not closed one penny by expanding the tax base and tapping new sources of revenue. Closing the gap should focus on just that. Policy decisions must be made in a much more public forum without the cover of closing the tax gap -- which is clearly and correctly perceived by the public to be solely an enforcement issue."

The AICPA also said it believes "increasing the use of the estimated payment system is a far inferior solution than the opposite solution of increasing the use of the more perfect withholding system."

The comments to the House Ways and Means Committee and Senate Finance Committee include the AICPA's observations on the JCT proposals; description of the issues that should be considered before any change is made with respect to the employment or self-employment tax for S corporation shareholders and partners; and recommendations to effectuate tax compliance without unduly burdening the current tax system.