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No matter how much they hate the IRS, honest Americans might well think of the restrictions put on it as a back-door tax hike brought to them by the very congressmen who promise lower taxes.

That's one effect of the bureaucratic and budgetary restraints put on the Internal Revenue Service's ability to go after wealthy tax cheats because every dollar those folks don't pay has to be made up by someone else. And guess who that someone else will be?

That's the tradeoff taxpayers must ponder as they enjoy life under a new "customer friendly" IRS that hassles taxpayers less for honest mistakes and helps them clear up those mistakes more quickly. That was the stated intent of congressional reforms mandated last year after much-publicized hearings at which taxpayers detailed harrowing tales of abuse at the hands of overzealous agents.

But accounts both on and off the record by those inside the agency indicate that in trying to stem abuses, Congress has created an IRS both unable and unwilling to recoup an estimated $200 billion in unpaid taxes owed each year.

The agency's staffing is down by 13,000 in just the past four years. That means investigations and collections also are down, officials say.

Combine that staff cut with the redeployment of seasoned agents into customer-service activities -- like answering phones -- to comply with Congress' demands, and the impact on enforcement is even greater than the personnel reduction alone would suggest.

The results can be seen on the stat sheet: The number of liens placed against suspected tax delinquents dropped from 544,000 in 1997 to just 167,867 last fiscal year. Taxpayer audits dropped from 1.5 million to 1.2 million and will hit a record low this year. And property seizures dropped from more than 10,000 to just 161.

It strains credulity to suggest that such big drops result purely from the elimination of taxpayer harassment.

Along with the drop in activity is the shift in focus from going after wealthy tax cheats -- who can hire a lawyer or call a member of Congress to complain -- to targeting more of the working poor, who can't pull such strings. Agents talking off the record told the New York Times recently that they're afraid of riling influential taxpayers and their congressional protectors.

As a result, audits of the wealthy and most businesses will drop sharply at the same time that there will be a new emphasis on finding those who abuse the Earned Income Tax Credit -- a program for the working poor long hated by congressional Republicans.

Put it all together and it's not a reassuring picture, either for those concerned about fairness or those concerned about their tax burden.

IRS Commissioner Charles Rossotti, a management expert brought in to reform the agency, says the shift in emphasis toward customer service makes sense because 98 percent of the revenue collected comes from voluntary compliance. To that degree, helping taxpayers understand how to comply makes sense because it increases that revenue.

But de-emphasizing audits of the wealthy -- either because of staff cuts or political timidity -- makes no sense. Willie Sutton said he robbed banks because that's where the money is. If the IRS really wants to close the tax gap and relieve the burden on honest taxpayers, it should refocus its activities for the same reason.