[JPRT 107-5-2]
[From the U.S. Government Publishing Office]



                        [JOINT COMMITTEE PRINT]
 
                        ESTIMATES OF FEDERAL TAX
                            EXPENDITURES FOR
                         FISCAL YEARS 2003-2007




                            Prepared for the

                      COMMITTEE ON WAYS AND MEANS

                                and the

                          COMMITTEE ON FINANCE

                               __________

                          By the Staff of the

                      JOINT COMMITTEE ON TAXATION

[GRAPHICS NOT AVAILABLE IN TIFF FORMAT]


                           DECEMBER 19, 2002


                                ________

                           U.S. GOVERNMENT PRINTING OFFICE
83-132                          WASHINGTON : 2002                 JCS-5-2











                            C O N T E N T S

                                                                   Page
Introduction.....................................................     1

 I. The Concept of Tax Expenditures...................................2

II. Measurement of Tax Expenditures..................................15

III.Tax Expenditure Estimates........................................17


        Table 1. Tax Expenditure Estimates by Budget Function, 
            Fiscal Years 2003-2007...............................    18

        Table 2. Distribution of All Returns, Taxable Returns, 
            Itemized Returns, and Tax Liability by Income Class..    28

        Table 3. Distribution of Selected Individual Tax 
            Expenditures by Income Class.........................    29













                              INTRODUCTION

    This report \1\ on tax expenditures for fiscal years 2003-
2007 is prepared by the staff of the Joint Committee on 
Taxation (``Joint Committee staff'') for the House Committee on 
Ways and Means and the Senate Committee on Finance. The report 
also is submitted to the House and Senate Committees on the 
Budget.
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    \1\ This report may be cited as follows: Joint Committee on 
Taxation, Estimates of Federal Tax Expenditures for Fiscal Years 2003-
2007 (JCS-5-02), December 19, 2002.
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    As in the case of earlier reports,\2\ the estimates of tax 
expenditures in this report were prepared in consultation with 
the staff of the Office of Tax Analysis in the Treasury 
Department (``the Treasury''). The Treasury published its 
estimates of tax expenditures for fiscal years 2001-2007 in the 
Administration's budgetary statement of February 2002.\3\ The 
lists of tax expenditures in this Joint Committee staff report 
and the Administration's budgetary statement overlap 
considerably; the differences are discussed in Part I of this 
report under the heading ``Comparisons with Treasury.''
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    \2\ Joint Committee on Taxation, Estimates of Federal Tax 
Expenditures, October 4, 1972, June 1, 1973, July 8, 1975, March 15, 
1976, March 16, 1977, March 14, 1978, March 15, 1979, March 6, 1980, 
March 16, 1981, March 8, 1982, March 7, 1983, November 9, 1984, April 
12, 1985, March 1, 1986, February 27, 1987, March 8, 1988, February 28, 
1989, March 9, 1990, March 11, 1991, April 24, 1992, April 22, 1993, 
November 9, 1994, September 1, 1995, November 26, 1996, December 15, 
1997, December 14, 1998, December 22, 1999, April 6, 2001, and January 
17, 2002.
    \3\ Office of Management and Budget, ``Tax Expenditures,'' Budget 
of the United States Government: Analytical Perspectives, Fiscal Year 
2003, February 4, 2002, pp. 95-127.
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    The Joint Committee staff has made its estimates (as shown 
in Table 1) based on the provisions in tax law as enacted 
through December 15, 2002. Expired or repealed provisions are 
not listed unless they have continuing revenue effects that are 
associated with ongoing taxpayer activity. Proposed extensions 
or modifications of expiring provisions are not included until 
they have been enacted into law.
    Part I of this report contains a discussion of the concept 
of tax expenditures. Part II is a discussion of the measurement 
of tax expenditures. Estimates of tax expenditures for fiscal 
years 2002-2006 are presented in Table 1 in Part III. Table 2 
shows the distribution of tax returns by income class, and 
Table 3 presents distributions of selected individual tax 
expenditures by income class.

                   I. THE CONCEPT OF TAX EXPENDITURES

Overview
    ``Tax expenditures'' are defined under the Congressional 
Budget and Impoundment Control Act of 1974 (``the Budget Act'') 
as ``revenue losses attributable to provisions of the Federal 
tax laws which allow a special exclusion, exemption, or 
deduction from gross income or which provide a special credit, 
a preferential rate of tax, or a deferral of tax liability.'' 
\4\ Thus, tax expenditures include any reductions in income tax 
liabilities that result from special tax provisions or 
regulations that provide tax benefits to particular taxpayers.
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    \4\ Congressional Budget and Impoundment Control Act of 1974 (P.L. 
93-344), sec. 3(3).
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    Special income tax provisions are referred to as tax 
expenditures because they may be considered to be analogous to 
direct outlay programs, and the two can be considered as 
alternative means of accomplishing similar budget policy 
objectives. Tax expenditures are similar to those direct 
spending programs that are available as entitlements to those 
who meet the statutory criteria established for the programs.
    Estimates of tax expenditures are prepared for use in 
budget analysis. They are a measure of the economic benefits 
that are provided through the tax laws to various groups of 
taxpayers and sectors of the economy. The estimates also may be 
useful in determining the relative merits of achieving 
specified public goals through tax benefits or direct outlays.
    The legislative history of the Budget Act indicates that 
tax expenditures are to be defined with reference to a normal 
income tax structure (referred to here as ``normal income tax 
law''). The determination of whether a provision is a tax 
expenditure is made on the basis of a broad concept of income 
that is larger in scope than ``income'' as defined under 
general U.S. income tax principles. The Joint Committee staff 
has used its judgment in distinguishing between those income 
tax provisions (and regulations) that can be viewed as a part 
of normal income tax law and those special provisions that 
result in tax expenditures. A provision traditionally has been 
listed as a tax expenditure by the Joint Committee staff if 
there is a reasonable basis for such classification and the 
provision results in more than a de minimis revenue loss, which 
solely for this purpose means a total revenue loss of at least 
$50 million over the five fiscal years 2003-2007. The Joint 
Committee staff emphasizes, however, that in the process of 
listing tax expenditures, no judgment is made, nor any 
implication intended, about the desirability of any special tax 
provision as a matter of public policy.
    If a tax expenditure provision were eliminated, Congress 
might choose to continue financial assistance through other 
means rather than terminate all Federal assistance for the 
activity. If a replacement spending program were enacted, the 
higher revenues received as a result of the elimination of a 
tax expenditure might not represent a net budget gain. A 
replacement program could involve direct expenditures, direct 
loans or loan guarantees, regulatory activity, a mandate, a 
different form of tax expenditure, or a general reduction in 
tax rates. Joint Committee staff estimates of tax expenditures 
do not anticipate such policy responses.
    The Budget Act uses the term tax expenditure to refer to 
the special tax provisions that are contained in the Federal 
income taxes on individuals and corporations.\5\ Other Federal 
taxes such as excise taxes, employment taxes, and estate and 
gift taxes may also have exceptions, exclusions, and credits, 
but those special tax provisions are not included in this 
report because they are not part of the income tax. Thus, for 
example, the income tax exclusion for employer-paid health 
insurance is included, but the Federal Insurance Contributions 
Act (``FICA'') tax exclusion for employer-paid health insurance 
is not treated as a tax expenditure.\6\
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    \5\ The Federal income tax on individuals also applies to estates 
and trusts, which are subject to a separate income tax rate schedule 
(Internal Revenue Code section 1(e)). Estates and trusts may benefit 
from some of the same tax expenditure provisions that apply to 
individuals. In Table 1 of this report, the tax expenditures that apply 
to estates and trusts have been included in the estimates of tax 
expenditures for individual taxpayers.
    \6\ In its budget statement, the Treasury Department identifies tax 
expenditures in the unified transfer tax (the estate and gift tax and 
the generation-skipping transfer tax). See, Office of Management and 
Budget, ``Tax Expenditures,'' February 4, 2002, pp. 95-127. Other 
analysts have explored applying the concept of tax expenditures to the 
payroll and excise taxes. See, Jonathan Barry Forman, ``Would a Social 
Security Tax Expenditure Budget Make Sense?'' Public Budgeting and 
Financial Management, 5, 1993, pp. 311-335, and Bruce F. Davie, ``Tax 
Expenditures in the Federal Excise Tax System,'' National Tax Journal, 
XLVII, March 1994, pp. 39-62.
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    Some provisions in the Internal Revenue Code provide for 
special tax treatment that is less favorable than normal income 
tax law. Examples of such provisions include (1) the denial of 
deductions for certain lobbying expenses, (2) the denial of 
deductions for certain executive compensation, and (3) the two-
percent floor on itemized deductions for unreimbursed employee 
expenses. Tax provisions that provide treatment less favorable 
than normal income tax law are not shown in this report because 
they are not included in the statutory definition of a tax 
expenditure.
Individual Income Tax
    Under the Joint Committee staff methodology, the normal 
structure of the individual income tax includes the following 
major components: one personal exemption for each taxpayer and 
one for each dependent, the standard deduction, the existing 
tax rate schedule, and deductions for investment and employee 
business expenses. Most other tax benefits to individual 
taxpayers can be classified as exceptions to normal income tax 
law.
    The Joint Committee staff views the personal exemptions and 
the standard deduction as defining the zero-rate bracket that 
is a part of normal tax law. Those itemized deductions that are 
not necessary for the generation of income are classified as 
tax expenditures, but only to the extent that they exceed the 
standard deduction level.
    All employee compensation is subject to tax unless the tax 
code contains a specific exclusion for the income. There are 
specific exclusions for the following employer-provided 
benefits: coverage under accident and health plans,\7\ accident 
and disability insurance, group term life insurance, 
educational assistance, transportation benefits (parking, van 
pools, and transit passes), child care, meals and lodging 
furnished for the convenience of the employer, employee awards, 
and other miscellaneous fringe benefits (e.g., employee 
discounts, services provided to employees at no additional cost 
to employers, tuition reductions, and de minimis fringe 
benefits). Each of these exclusions is classified as a tax 
expenditure in this report.
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    \7\ Present law contains an exclusion for employer-provided 
coverage under accident and health plans (sec. 106 of the Internal 
Revenue Code of 1986, the ``Code'') and an exclusion for benefits 
received by employees under employer-provided accident and health plans 
(Code sec. 105(b)). These two exclusions are viewed as a single tax 
expenditure. Under normal income tax law, the value of employer-
provided accident and health coverage would be includable in the income 
of employees, but employees would not be subject to tax on the accident 
and health insurance benefits (reimbursements) that they might receive.
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    Under normal income tax law, employer contributions to 
pension plans and income earned on pension assets would be 
taxable to employees as the contributions are made and as the 
income is earned, and employees would not receive any deduction 
or exclusion for their pension contributions. Under present 
law, employer contributions to qualified pension plans and 
employee contributions made at the election of the employee 
through salary reduction are not taxed until distributed to the 
employee, and income earned on pension assets is not taxed 
until distributed. The tax expenditure for ``net exclusion of 
pension contributions and earnings'' is computed as the income 
taxes forgone on current tax-excluded pension contributions and 
earnings less the income taxes paid on current pension 
distributions (including the 10-percent additional tax paid on 
early withdrawals from pension plans).
    Under present law, social security and tier 1 railroad 
retirement benefits are fully or partially excluded from gross 
income.\8\ Under normal income tax law, retirees would be 
entitled to an exclusion for only the portion of the retirement 
benefits that represents a return of the payroll taxes that 
they paid during their working years. Thus, the exclusion of 
social security and railroad retirement benefits in excess of 
payroll tax payments is classified as a tax expenditure.
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    \8\ For taxpayers with modified adjusted gross incomes above 
certain levels, up to 85 percent of social security retirement benefits 
are includable in income.
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    All Medicare benefits are excluded from taxation. The value 
of Medicare Part A insurance generally is greater than the 
Health Insurance (``HI'') tax contributions that enrollees made 
during their working years, and the value of Medicare Part B 
insurance generally is greater than the Part B premium that 
enrollees must pay. The exclusion of the value of Medicare Part 
A insurance in excess of HI tax contributions is classified as 
a tax expenditure, and the exclusion of the value of Medicare 
Part B insurance in excess of premiums paid also is classified 
as a tax expenditure.
    Public assistance benefits are excluded from gross income 
by statute or by Internal Revenue Service regulations. Table 1 
contains tax expenditure estimates for workers' compensation 
benefits, special benefits for disabled coal miners, and cash 
public assistance benefits (which include Supplemental Security 
Income benefits and Temporary Assistance for Needy Families 
benefits).
    The individual income tax does not include in gross income 
the imputed income that individuals receive from the services 
provided by owner-occupied homes and durable goods.\9\ However, 
the Joint Committee staff does not classify this exclusion as a 
tax expenditure. The measurement of imputed income for tax 
purposes presents administrative problems and its exclusion 
from taxable income may be regarded as an administrative 
necessity.\10\
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    \9\ The National Income and Product Accounts include estimates of 
this imputed income. The accounts appear in U.S. Department of 
Commerce, Bureau of Economic Analysis, Survey of Current Business, 
published monthly.
    \10\ If the imputed income from owner-occupied homes were included 
in adjusted gross income, it would be proper to include all mortgage 
interest deductions and related property tax deductions as part of the 
normal income tax structure, since interest and property tax deductions 
would be allowable as a cost of producing imputed income. It also would 
be appropriate to allow deductions for depreciation and maintenance 
expenses for owner-occupied homes.
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    Under normal income tax law, individuals would be allowed 
to deduct only the interest on indebtedness incurred in 
connection with a trade or business or an investment. Thus, the 
deduction for mortgage interest on a principal or second 
residence is classified as a tax expenditure.
    The Joint Committee staff assumes that, for administrative 
feasibility, normal income tax law would tax capital gains in 
full in the year the gains are realized through sale or 
exchange. Thus, the deferral of tax until realization is not 
classified as a tax expenditure, but reduced rates of tax, 
further deferrals of tax (beyond the year of sale or exchange), 
and exclusions of certain capital gains are classified as tax 
expenditures.
    It also is assumed that normal income tax law would not 
provide for any indexing of the basis of capital assets for 
changes in the general price level. Thus, under normal income 
tax law (as under present law), the income tax would be levied 
on nominal gains as opposed to real gains in asset values.
    There are many types of State and local government bonds 
and private purpose bonds that qualify for tax-exempt status 
for Federal income tax purposes. Table 1 contains a separate 
tax expenditure listing for each type of bond.
    Under the Joint Committee staff view of normal tax law, 
compensatory stock options would be subject to regular income 
tax at the time the options are exercised and employers would 
receive a corresponding tax deduction.\11\ The employee's 
income would be equal to the difference between the purchase 
price of the stock and the market price on the day the option 
is exercised. Present law provides for special tax treatment 
for incentive stock options and options acquired under employee 
stock purchase plans. When certain requirements are satisfied, 
(1) the income that is received at the time the option is 
exercised is excluded for purposes of the regular income tax 
but included for purposes of the alternative minimum tax, (2) 
the gain from any subsequent sale of the stock is taxed as a 
capital gain, and (3) the employer does not receive a tax 
deduction with respect to the option. The special tax treatment 
provided to the employee is viewed as a tax expenditure by the 
Joint Committee staff, and an estimate of this tax expenditure 
is contained in Table 1. However, it should be noted that the 
revenue loss from the special tax treatment provided to the 
employee is accompanied by a significant revenue gain from the 
denial of the deduction to the employer.
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    \11\ If the option has a readily ascertainable fair market value, 
normal law would tax the option at the time it is granted and the 
employer would be entitled to a deduction at that time.
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    The individual alternative minimum tax (``AMT'') and the 
passive activity loss rules are not viewed by the Joint 
Committee staff as a part of normal income tax law. Instead, 
they are viewed as provisions that reduce the magnitude of the 
tax expenditures to which they apply. For example, the AMT 
reduces the value of the deduction for State and local income 
taxes (for those taxpayers subject to the AMT) by not allowing 
the deductions to be claimed in the calculation of AMT 
liability. Similarly, the passive loss rules defer otherwise 
allowable deductions and credits from passive activities until 
a time when the taxpayer has passive income or disposes of the 
assets associated with the passive activity. Exceptions to the 
individual AMT and the passive loss rules are not classified as 
tax expenditures by the Joint Committee staff because the 
effects of the exceptions already are incorporated in the 
estimates of related tax expenditures.
Business Income Taxation
    Regardless of the legal form of organization (sole 
proprietorship, partnership, or S or C corporation), the same 
general principles are used in the computation of taxable 
business income. Thus, most business tax expenditures apply 
equally to unincorporated and incorporated businesses.
    One of the most difficult issues in defining tax 
expenditures for business income relates to the tax treatment 
of capital costs. Under present law, capital costs may be 
recovered under a variety of alternative methods, depending 
upon the nature of the costs and the status of the taxpayer. 
For example, investments in equipment and structures may 
qualify for tax credits, expensing, accelerated depreciation, 
or straight-line depreciation. The Joint Committee staff 
generally classifies as tax expenditures cost recovery 
allowances that are more favorable than those provided under 
the alternative depreciation system (sec. 168(g)), which 
provides for straight-line recovery over tax lives that are 
longer than those permitted under the accelerated system.
    As indicated above, the Joint Committee staff assumes that 
normal income tax law would not provide for any indexing of the 
basis of capital assets. Thus, normal income tax law would not 
take into account the effects of inflation on tax depreciation.
    The Joint Committee staff uses several accounting standards 
in evaluating the provisions in the Code that govern the 
recognition of business receipts and expenses. Under the Joint 
Committee staff view, normal income tax law is assumed to 
require the accrual method of accounting, the standard of 
``economic performance'' (used in the Code to test whether 
liabilities are deductible), and the general concept of 
matching income and expenses. In general, tax provisions that 
do not satisfy all three standards are viewed as tax 
expenditures. For example, the deduction for contributions to 
taxpayer-controlled mining reclamation reserve accounts is 
viewed as a tax expenditure because the contributions do not 
satisfy the economic performance standard. (Adherence to the 
standard would require that the taxpayer make an irrevocable 
contribution toward future reclamation, involving a trust fund 
or similar mechanism, as occurs in a number of areas in the 
Code.) The deduction for contributions to nuclear 
decommissioning trust accounts is not viewed as a tax 
expenditure because the contributions are irrevocable (i.e., 
they satisfy the economic performance standard). However, 
present law provides for a reduced rate of tax on the income of 
nuclear decommissioning trust accounts, and this reduced rate 
of tax is viewed as a tax expenditure.
    The Joint Committee staff assumes that normal income tax 
law would provide for the carryback and carryforward of net 
operating losses. The staff also assumes that the general 
limits on the number of years that such losses may be carried 
back or forward were chosen for reasons of administrative 
convenience and compliance concerns and may be assumed to 
represent normal income tax law. Exceptions to the general 
limits on carrybacks and carryforwards are viewed as tax 
expenditures.
Corporate Income Tax
    The income of corporations (other than S corporations) 
generally is subject to the corporate income tax. The corporate 
income tax includes a graduated tax rate schedule. The lower 
tax rates in the schedule are classified by the Joint Committee 
staff as a tax expenditure (as opposed to normal income tax 
law) because they are intended to provide tax benefits to small 
business and, unlike the graduated individual income tax rates, 
are unrelated to concerns about ability of individuals to pay 
taxes.
    Exceptions to the corporate alternative minimum tax are not 
viewed as tax expenditures because the effects of the AMT 
exceptions are already incorporated in the estimates of related 
tax expenditures.\12\
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    \12\ See discussion of individual AMT on page 6.
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    Certain income of pass-through entities is exempt from the 
corporate income tax. The income of sole proprietorships, S 
corporations, and most partnerships is taxed only at the 
individual level. The special tax rules for these pass-through 
entities are not classified as tax expenditures because the tax 
benefits are available to any entity that chooses to organize 
itself and operate in the required manner.
    Nonprofit corporations that satisfy the requirements of 
Code section 501 also generally are exempt from corporate 
income tax. The tax exemption of certain nonprofit cooperative 
business organizations, such as trade associations, is not 
treated as a tax expenditure for the same reason applicable to 
for-profit pass-through business entities. With respect to 
other nonprofit organizations, such as charities, tax-exempt 
status is not classified as a tax expenditure because the 
nonbusiness activities of such organizations generally must 
predominate and their unrelated business activities are subject 
to tax. In general, the imputed income derived from nonbusiness 
activities conducted by individuals or collectively by certain 
nonprofit organizations is outside the normal income tax base. 
However, the ability of donors to such nonprofit organizations 
to claim a charitable contribution deduction is a tax 
expenditure (because such contributions do not generate income 
to the donor), as is the exclusion of income granted to holders 
of tax-exempt financing issued by charities.

Recent Legislation

    The Job Creation and Worker Assistance Act of 2002 (H.R. 
3090), enacted on March 9, 2002 (P.L. 107-147), included 
several new tax expenditures, as follows:
    --An additional first-year depreciation deduction was 
provided for qualified property to which the general rules of 
MACRS apply. Qualified property includes (1) property with a 
recovery period of 20 years or less, (2) water utility 
property, (3) computer software other than software covered by 
section 197, and (4) leasehold improvement property. The 
original use of the property must commence with the taxpayer, 
the taxpayer must purchase (or begin construction of) the 
property after September 11, 2001, and before September 11, 
2004, and the property must be placed in service on or after 
September 11, 2001 (except for certain leased property) and 
before January 1, 2005.
    --An above-the-line deduction was provided for up to $250 
per year of expenses paid or incurred by an eligible educator 
for books, supplies, computer equipment, and other equipment 
and materials used in the classroom. The expenses must be 
otherwise deductible under section 162 as trade or business 
expenses. An eligible educator is a kindergarten through grade 
12 teacher, instructor, aide, counselor, or principal in a 
school for at least 900 hours during the school year. The 
provision is effective for taxable years beginning after 
December 31, 2001, and before January 1, 2004.
    The Job Creation and Worker Assistance Act also provided a 
number of tax incentives for the area of New York City that was 
damaged in the terrorist attacks of September 11, 2001. These 
tax incentives apply only in the ``New York Liberty Zone,'' 
which is the area located on or south of Canal Street, south of 
East Broadway (east of its intersection with Canal Street), and 
south of Grand Street (east of its intersection with East 
Broadway) in the Borough of Manhattan. The tax incentives are 
as follows:
    --The work opportunity tax credit (``WOTC'') was expanded 
to include a new targeted group consisting of individuals who 
perform all their services for a business located in the New 
York Liberty Zone and individuals who perform substantially all 
their services in New York City for a business that relocated 
from the Liberty Zone elsewhere within New York City due to the 
destruction or damage of their workplaces by the terrorist 
attacks. This expansion of the WOTC is effective for wages paid 
or incurred for work performed after December 31, 2001, and 
before January 1, 2004.
    --An additional first-year depreciation deduction was 
provided for qualified New York Liberty Zone property. The 
deduction is equal to 30 percent of the adjusted basis of the 
qualified property. The original use of the property must 
commence with the taxpayer on or after September 11, 2001 
(except for certain leased property) and the property must be 
acquired by the taxpayer by purchase after September 10, 2001, 
and placed in service on or before December 31, 2006. For 
qualifying nonresidential real property and residential rental 
property, the property must be placed in service on or before 
December 31, 2009.
    --Authority was provided to issue $8 billion of tax-exempt 
private activity bonds to finance the construction and 
rehabilitation of nonresidential real property and residential 
rental real property in the New York Liberty Zone. The 
provision is effective for bonds issued before January 1, 2005.
    --Authority was provided for one additional advance 
refunding for certain bonds for facilities located in New York 
City. The authority applies only to bonds for which all 
present-law advance refunding authority was exhausted before 
September 12, 2001, and with respect to which the advance 
refunding bonds authorized under present law were outstanding 
on September 11, 2001. The maximum amount of advance refunding 
authorized under this provision is $9 billion. The advance 
refunding must occur before January 1, 2005.
    --The limits on section 179 expensing were increased for 
qualified property used in the New York Liberty Zone. The 
maximum amount that may be expensed under section 179 was 
increased by the lesser of (1) $35,000 or (2) the cost of 
qualifying property placed in service during the taxable year. 
Qualifying property is section 179 property that is purchased 
and placed in service by the taxpayer in the New York Liberty 
Zone in the active conduct of a trade or business by the 
taxpayer. The use of the property in the New York Liberty Zone 
must commence with the taxpayer. The provision is effective for 
taxable years beginning after December 31, 2001, and before 
January 1, 2007.
    --The replacement period for section 1033 involuntary 
conversions was extended from two years to five years for 
property that was involuntarily converted within the New York 
Liberty Zone as a result of the terrorist attacks that occurred 
on September 11, 2001. The five-year replacement period is 
available only if substantially all of the use of the 
replacement property is in New York City. The provision is 
effective for involuntary conversions occurring on or after 
September 11, 2001.
    --A five-year recovery period was provided for qualified 
New York Liberty Zone (``NYLZ'') leasehold improvement 
property. Qualified NYLZ leasehold improvement property is 
property defined in section 168(e)(6) that is placed in service 
after September 10, 2001, and before January 1, 2007, in the 
New York Liberty Zone. The straight-line method is required to 
be used with respect to qualified NYLZ leasehold improvement 
property.
    In Table 1, the effects of all of the New York Liberty Zone 
tax provisions are combined in the tax expenditure estimate for 
``New York Liberty Zone tax incentives.''
    The Job Creation and Worker Assistance Act also modified 
several tax expenditures, as follows:
    --The non-accrual experience method of accounting was 
restricted to amounts received for the performance of certain 
professional services and for services provided by certain 
small businesses, effective for taxable years ending after the 
date of enactment. This change is reflected in the tax 
expenditure estimate for ``cash accounting, other than 
agriculture.''
    --The exclusion for qualified foster care payments was 
modified in two ways. First, the definition of qualified foster 
care payments was expanded to include payments by any placement 
agency that is licensed or certified by a State or local 
government, or an entity designated by a State or local 
government to make payments to providers of foster care. 
Second, the definition of a qualified foster care individual 
was expanded to include all individuals placed by a qualified 
foster care placement agency, regardless of age at time of 
placement. The changes are effective for taxable years 
beginning after December 31, 2001.
    The Job Creation and Worker Assistance Act also extended a 
number of expiring tax expenditure provisions, as follows:
    --The phaseout of the tax credit for electric vehicles, 
which was scheduled to commence in 2002, was deferred until 
2004. Thus, the credit will be reduced by 25 percent for 
property placed in service in 2004, 50 percent for property 
placed in service in 2005, 75 percent for property placed in 
service in 2006, and the credit will be unavailable for 
property placed in service in 2007 and thereafter.
    --The tax credit for electricity production from wind, 
closed-loop biomass, and poultry litter, which was scheduled to 
expire for property placed in service after December 31, 2001, 
was extended for two years. Thus, the credit will be available 
for property placed in service prior to January 1, 2004.
    --The work opportunity tax credit, which was scheduled to 
expire for wages paid or incurred to employees who began work 
after December 31, 2001, was extended for two years. Thus, the 
credit will be available for wages paid or incurred to 
employees who begin work before January 1, 2004.
    --The welfare-to-work tax credit, which was scheduled to 
expire for wages paid or incurred to individuals who began work 
after December 31, 2001, was extended for two years. Thus, the 
credit will be available for wages paid or incurred to 
qualified individuals who begin work before January 1, 2004.
    --The phaseout of the deduction for clean-fuel vehicles, 
which was scheduled to commence in 2002, was deferred until 
2004. Thus, the deduction will be reduced by 25 percent for 
property placed in service in 2004, 50 percent for property 
placed in service in 2005, 75 percent for property placed in 
service in 2006, and the deduction will be unavailable for 
property placed in service in 2007 and thereafter.
    --The suspension of the 100-percent-of-net-income limit on 
percentage depletion for marginal wells, which was scheduled to 
expire for taxable years beginning after December 31, 2001, was 
extended to include taxable years beginning in 2002 and 2003.
    --The authority to issue qualified zone academy bonds, 
which was scheduled to expire after 2001, was extended for two 
years. Up to $400 million of qualified zone academy bonds may 
be issued each year in calendar years 2002 and 2003.
    --The cut-off year for Archer medical savings accounts 
(``MSAs'') was changed from 2002 to 2003. After the cut-off 
year, no new contributions may be made to Archer MSAs except by 
individuals who had previously made Archer MSA contributions 
and employees who are employed by MSA-participating employers.
    --The Indian employment tax credit, which was scheduled to 
expire for wages paid after December 31, 2003, was extended for 
one year. Thus, the credit will be available for wages paid 
before January 1, 2005. The accelerated depreciation provisions 
for Indian reservation property, which were scheduled to expire 
for property placed in service after December 31, 2003, were 
also extended one year. Thus, the accelerated depreciation will 
be available for property placed in service prior to January 1, 
2005. In Table 1, these two items are combined in the tax 
expenditure estimate for ``Indian reservation tax incentives.''
    --The exemptions from Subpart F for the active financing 
income of controlled foreign corporations, which were scheduled 
to expire for taxable years beginning after December 31, 2001, 
were extended for five years. The extension is effective for 
taxable years of foreign corporations beginning after December 
31, 2001, and before January 1, 2007, and for taxable years of 
U.S. shareholders with or within which such taxable years of 
such foreign corporations end.
    The Clergy Housing Allowance Clarification Act of 2002 
(H.R. 4156), enacted on May 20, 2002 (P.L. 107-181), limited 
the exclusion for parsonage allowances to the fair market 
rental value of the home. The provision is generally effective 
for taxable years beginning after December 31, 2001.
    The Trade Act of 2002 (H.R. 3009), enacted on August 6, 
2002 (P.L. 107-210), provided a new 65-percent refundable tax 
credit for the purchase of health insurance coverage by certain 
taxpayers eligible for Trade Adjustment Assistance (``TAA'') 
and certain Pension Benefits Guaranty Corporation (``PBGC'') 
pension recipients. The credit is effective for eligible health 
insurance premiums paid for coverage after the date of 
enactment.
    The Holocaust Restitution Tax Fairness Act of 2002 (H.R. 
4823), enacted on December 17, 2002, extended the exclusion for 
restitution payments received by victims of the Nazi regime and 
the victims' heirs and estates. The exclusion was scheduled to 
expire for taxable years beginning after December 31, 2010.

Comparisons with Treasury Department

    The Joint Committee staff and Treasury lists of tax 
expenditures differ in three respects. First, the Treasury uses 
a different classification of those provisions that can be 
considered a part of normal income tax law under both the 
individual and business income taxes. In general, the Joint 
Committee staff methodology involves a narrower concept of 
normal income tax law. Thus, the Joint Committee list of tax 
expenditures includes some provisions that are not contained in 
the Treasury list. The cash method of accounting provides an 
example. The Treasury considers the cash accounting option for 
certain businesses to be a part of normal income tax law, but 
the Joint Committee staff methodology treats it as a departure 
from normal income tax law that constitutes a tax expenditure.
    Second, the Joint Committee staff and Treasury estimates of 
tax expenditures span slightly different sets of years. The 
Treasury's estimates cover a seven-year period--the last fiscal 
year, the current fiscal year when the President's budget is 
submitted, and the next five fiscal years, i.e., fiscal years 
2001-2007. The Joint Committee staff estimates cover the 
current fiscal year and the succeeding four fiscal years, i.e., 
fiscal years 2003-2007.
    Third, the Joint Committee staff list excludes those 
provisions that are estimated to result in revenue losses below 
the de minimis amount, i.e. less than $50 million over the five 
fiscal years 2003 through 2007. The Treasury rounds all yearly 
estimates to the nearest $10 million and excludes those 
provisions with estimates that round to zero in each year, i.e. 
provisions that result in less than $5 million in revenue loss 
in each of the years 2001 through 2007.
    For the past nine years, the President's budget has 
contained a section that reviews and tabulates the estate and 
gift tax provisions that the Treasury considers as tax 
expenditures. The Joint Committee staff considers estate and 
gift tax provisions as being outside of the normal income tax 
structure and thus omits them from its list of tax 
expenditures.
    In some cases, two or more of the tax expenditure items in 
the Treasury list have been combined into a single item in the 
Joint Committee staff list, and vice versa. The Table 1 
descriptions of some tax expenditures also may vary from the 
descriptions used by the Treasury.
    The following is a list of tax provisions that are 
contained in the Joint Committee staff list of tax expenditures 
(and are shown in Table 1) but are not contained in the 
Treasury list:

Natural resources and environment

--Exclusion of contributions in aid of construction for water 
            and sewer utilities
--Special rules for mining reclamation reserves
--Special tax rate for nuclear decommissioning reserve funds

Agriculture

--Exclusion of cost-sharing payments
--Cash accounting for agriculture
--Five-year carryback period for net operating losses 
            attributable to farming

Insurance companies

--Special treatment of life insurance company reserves
--Deduction of unpaid loss reserves of property and casualty 
            companies

Business and commerce

--Expensing of magazine circulation expenditures
--Special rules for magazine, paperback book, and record 
            returns
--Completed contract rules
--Cash accounting, other than agriculture
--Deferral of gain on like-kind exchanges
--Exception from net operating loss limitations for 
            corporations in bankruptcy
--Tax credit for employer-paid FICA taxes on tips
--Deferral of gain on involuntary conversions resulting from 
            Presidentially-declared disasters

Employment

--Exclusion of miscellaneous fringe benefits
--Exclusion of employee awards
--Exclusion of income earned by voluntary employee beneficiary 
            associations
--Exclusion of spread on acquisition of stock under incentive 
            stock option plans and employee stock purchase 
            plans

Medicare

--Exclusion of untaxed Medicare benefits for Hospital Insurance
--Exclusion of untaxed Medicare benefits for Supplementary 
            Medical Insurance

    The following tax provisions are not included in the Joint 
Committee staff list of tax expenditures or the Treasury list. 
However, these provisions are viewed as tax expenditures by the 
Joint Committee staff. These provisions are not listed in Table 
1 because the estimated revenue losses for fiscal years 2003 
through 2007 are below the de minimis amount ($50 million):

Energy

--Expensing of tertiary injectants

Financial institutions

--Exclusion of investment income from structured settlement 
            arrangements

Income security

--Exclusion of survivor annuities paid to families of public 
            safety officers killed in the line of duty

Social services

--Exclusion of restitution payments received by victims of the 
            Nazi regime and the victims' heirs and estates

    The following is a list of the tax provisions that are 
included in the Treasury list and are viewed as tax 
expenditures by the Joint Committee staff but are excluded from 
Table 1 because the estimated revenue losses for fiscal years 
2003 through 2007 are below the de minimis amount ($50 
million):

Energy

--Tax credit for electric vehicles
--Deductions for clean-fuel vehicles and refueling property

Natural resources and environment

--Tax credit and seven-year amortization for reforestation 
            expenditures

Agriculture

--Deferral of tax on gains from the sale of stock in a 
            qualified refiner or processor to an eligible 
            farmer's cooperative

Financial institutions

--Bad debt reserves of financial institutions

Insurance companies

--Special alternative tax on small property and casualty 
            insurance companies
--Tax exemption for certain small insurance companies

Business and commerce

--Exclusion of income from discharge of indebtedness incurred 
            in connection with qualified real property

Social services

--Expensing of costs for removing architectural barriers

    There are three additional tax expenditure provisions in 
the Treasury list that are not included in the Joint Committee 
staff list. Two of the provisions involve exceptions to the 
passive loss rules: the exception for working interests in oil 
and gas properties, and the exception for up to $25,000 of 
rental losses. The Joint Committee staff does not classify 
these two provisions as tax expenditures; the effects of the 
passive loss rules (and exceptions to the rules) are included 
in the estimates of the tax expenditure provisions that are 
affected by the rules.\13\ The third tax expenditure in the 
Treasury list that is not included in the Joint Committee staff 
list is the exemption of certain income of telephone and 
electric cooperatives. The Joint Committee staff does not 
classify this provision as a tax expenditure because the 
special tax rules for pass-through entities are assumed to be a 
part of normal tax law.\14\
---------------------------------------------------------------------------
    \13\ See discussion of the alternative minimum tax and passive loss 
rules, above on page 6.
    \14\ See discussion on pages 7-8, above.

                  II. MEASUREMENT OF TAX EXPENDITURES

Tax Expenditure Estimates Generally
    A tax expenditure is measured by the difference between tax 
liability under present law and the tax liability that would 
result from a recomputation of tax without benefit of the tax 
expenditure provision. Taxpayer behavior is assumed to remain 
unchanged for tax expenditure estimate purposes.\15\
---------------------------------------------------------------------------
    \15\ An alternative way to measure tax expenditures is to express 
their values in terms of ``outlay equivalents.'' An outlay equivalent 
is the dollar size of a direct spending program that would provide 
taxpayers with net benefits that would equal what they now receive from 
a tax expenditure. The Treasury Department presents estimates of outlay 
equivalents in the President's budget in addition to presenting 
estimates in the same manner as the Joint Committee staff.
---------------------------------------------------------------------------
    The tax expenditure estimates in this report are based on 
Congressional Budget Office and Joint Committee staff 
projections of the gross income, deductions, and expenditures 
of individuals and corporations for calendar years 2002-2007. 
These projections are used to compute tax liabilities for the 
present-law revenue baseline and tax liabilities for the 
alternative baseline that assumes that the tax expenditure 
provision does not exist.
    Internal Revenue Service (``IRS'') statistics from recent 
tax returns are used to develop projections of the tax credits, 
deductions, and exclusions that will be claimed under the 
present-law baseline. These IRS statistics show the actual 
usage of the various tax expenditure provisions. In the case of 
some tax expenditures, such as the earned income credit, there 
is evidence that some taxpayers are not claiming all of the 
benefits to which they are entitled, while others are filing 
claims that exceed their entitlements. The tax expenditure 
estimates in this report are based on projections of actual 
claims under the various tax provisions, not the tax benefits 
to which taxpayers are entitled.
    Some tax expenditure estimates are based partly on 
statistics for income, deductions, and expenses for prior 
years. Accelerated depreciation is an example. Estimates for 
this tax expenditure are based on the difference between tax 
depreciation deductions under present law and the deductions 
that would have been claimed in the current year if investments 
in the current year and all prior years had been depreciated 
using the alternative (normal income tax law) depreciation 
system.
    Each tax expenditure is estimated separately, under the 
assumption that all other tax expenditures remain in the tax 
code. If two or more tax expenditures were estimated 
simultaneously, the total change in tax liability could be 
smaller or larger than the sum of the amounts shown for each 
item separately, as a result of interactions among the tax 
expenditure provisions.
    Year-to-year differences in the estimates for each tax 
expenditure reflect changes in tax law, including phaseouts of 
tax expenditure provisions and changes that alter the 
definition of the normal income tax structure, such as the tax 
rate schedule, the personal exemption amount, and the standard 
deduction. Some of the estimates for this tax expenditure 
report may differ from estimates made in previous years because 
of changes in law and economic conditions, the availability of 
better data, and improved estimating techniques.
Tax Expenditures versus Revenue Estimates
    A tax expenditure estimate is not the same as a revenue 
estimate for the repeal of the tax expenditure provision for 
three reasons. First, tax expenditure estimates do not 
incorporate any changes in taxpayer behavior, whereas revenue 
estimates incorporate the effects of the behavioral changes 
that are anticipated to occur in response to the repeal of a 
tax provision. Second, tax expenditure estimates are concerned 
with changes in the tax liabilities of taxpayers. Because the 
tax expenditure focus is on tax liabilities as opposed to 
Federal government tax receipts, there is no concern for the 
timing of tax payments. Revenue estimates are concerned with 
changes in Federal tax receipts which are affected by the 
timing of tax payments. Third, some of the tax provisions that 
provide an exclusion from income also apply to the FICA tax 
base, and the repeal of the income tax provision would 
automatically increase FICA tax revenues as well as income tax 
revenues. There may also be interactions between income tax 
provisions and other Federal taxes such as excise taxes and the 
estate and gift tax.
    If a tax expenditure provision were repealed, it is likely 
that the repeal would be made effective at the beginning of a 
calendar year. In this case, the revenue estimate for repeal 
would show a smaller revenue gain in the first fiscal year than 
in subsequent years, because the repeal would be occurring 
after the start of the government's fiscal year. The revenue 
estimate might also reflect some delay in the timing of the 
revenue gains as a result of the taxpayer tendency to postpone 
or forgo changes in tax withholding and estimated tax payments.

                     III. TAX EXPENDITURE ESTIMATES

    Tax expenditures are grouped in Table 1 in the same 
functional categories as outlays in the Federal budget. 
Estimates are shown separately for individuals and 
corporations. Those tax expenditures that do not fit clearly 
into any single budget category have been placed in the most 
appropriate category.
    Several of the tax expenditure items involve small amounts 
of revenue, and those estimates are indicated in Table 1 by 
footnote 1. For each of these items, the footnote means that 
the tax expenditure is less than $50 million in the fiscal 
year.
    Table 2 presents tax return information for each of nine 
income classes on the number of all returns (including filing 
and nonfiling units), the number of taxable returns, the number 
of returns with itemized deductions, and the amount of tax 
liability.
    Table 3 provides distributional estimates by income class 
for some of the tax expenditures that affect individual 
taxpayers. Not all tax expenditures that affect individuals are 
shown in this table because of the difficulty in making 
reliable estimates of the income distribution of items that do 
not appear on tax returns under present law.

                                     Table 1.--Tax Expenditure Estimates By Budget Function, Fiscal Years 2003-2007
                                                                  [Billions of dollars]
--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                     Corporations                                 Individuals
                      Function                      ------------------------------------------------------------------------------------------   Total
                                                       2003     2004     2005     2006     2007     2003     2004     2005     2006     2007    2003-07
--------------------------------------------------------------------------------------------------------------------------------------------------------
National Defense
  Exclusion of benefits and allowances to Armed      .......  .......  .......  .......  .......      2.5      2.6      2.6      2.7      2.8       13.1
   Forces personnel................................
  Exclusion of military disability benefits........  .......  .......  .......  .......  .......      0.1      0.1      0.1      0.1      0.1        0.6
International Affairs
  Exclusion of income earned abroad by U.S.          .......  .......  .......  .......  .......      3.0      3.2      3.4      3.6      3.8       17.0
   citizens........................................
  Exclusion of certain allowances for Federal        .......  .......  .......  .......  .......      0.4      0.4      0.5      0.5      0.6        2.4
   employees abroad................................
  Exclusion of extraterritorial income.............      4.8      5.0      5.3      5.7      6.0  .......  .......  .......  .......  .......       26.8
  Deferral of active income of controlled foreign        4.4      4.6      4.8      5.0      5.2  .......  .......  .......  .......  .......       24.0
   corporations....................................
  Inventory property sales source rule exception...      5.1      5.4      5.7      6.0      6.3  .......  .......  .......  .......  .......       28.5
  Deferral of certain financing income.............      1.7      1.9      2.1      2.3      1.7  .......  .......  .......  .......  .......        9.7
General Science, Space, and Technology
  Tax credit for qualified research expenditures...      5.1      4.5      2.7      1.4      0.7    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)       14.7
  Expensing of research and experimental                 3.8      4.7      5.4      5.9      6.2    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)       26.6
   expenditures....................................
Energy
  Expensing of exploration and development costs:
    Oil and gas....................................      0.6      0.4      0.3      0.4      0.5    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        2.2
    Other fuels....................................    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        0.2
  Excess of percentage over cost depletion:
    Oil and gas....................................      0.4      0.4      0.4      0.5      0.5    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        2.2
    Other fuels....................................    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        0.1
  Tax credit for enhanced oil recovery costs.......      0.2      0.2      0.2      0.2      0.2      0.1      0.1      0.1      0.1      0.1        1.5
  Tax credit for production of non-conventional          0.8      0.5      0.5      0.5      0.6      0.2      0.1      0.1      0.1      0.1        3.6
   fuels...........................................
  Tax credits for alcohol fuels \2\................    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)  .......  .......  .......  .......  .......        0.1
  Exclusion of interest on State and local             (\1\)    (\1\)    (\1\)    (\1\)    (\1\)      0.1      0.1      0.1      0.1      0.1        0.8
   government industrial development bonds for
   energy production facilities....................
  Exclusion of energy conservation subsidies         .......  .......  .......  .......  .......    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        0.1
   provided by public utilities....................
  Tax credit for investments in solar and              (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        0.1
   geothermal energy facilities....................
  Tax credit for electricity production from wind,     (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        0.3
   biomass, and poultry waste......................
Natural Resources and Environment
  Expensing of exploration and development costs,      (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        0.3
   nonfuel minerals................................
  Excess of percentage over cost depletion, nonfuel      0.1      0.1      0.1      0.1      0.1      0.1      0.1      0.1      0.1      0.1        0.8
   minerals........................................
  Expensing of multiperiod timber-growing costs....      0.2      0.2      0.2      0.2      0.2    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        0.9
  Exclusion of interest on State and local               0.2      0.2      0.2      0.2      0.2      0.4      0.4      0.4      0.4      0.5        3.1
   governments sewage, water, and hazardous waste
   facilities bonds................................
  Special rules for mining reclamation reserves....    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        0.2
  Special tax rate for nuclear decommissioning           0.3      0.3      0.3      0.3      0.3  .......  .......  .......  .......  .......        1.5
   reserve fund....................................
  Exclusion of contributions in aid of construction    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)  .......  .......  .......  .......  .......        0.1
   for water and sewer utilities...................
Agriculture
  Expensing of soil and water conservation             (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        0.2
   expenditures....................................
  Expensing of fertilizer and soil conditioner         (\3\)    (\1\)    (\1\)    (\1\)    (\1\)    (\3\)    (\1\)    (\1\)    (\1\)    (\1\)        0.1
   costs...........................................
  Expensing of the costs of raising dairy and          (\1\)    (\1\)    (\1\)    (\1\)    (\1\)      0.1    (\1\)    (\1\)    (\1\)    (\1\)        0.2
   breeding cattle.................................
  Exclusion of cost-sharing payments...............    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        0.1
  Exclusion of cancellation of indebtedness income   .......  .......  .......  .......  .......      0.1      0.1      0.1      0.1      0.1        0.4
   of farmers......................................
  Cash accounting for agriculture..................    (\1\)      0.1      0.1      0.1      0.1      0.4      0.6      0.6      0.6      0.6        3.2
  Income averaging for farmers.....................  .......  .......  .......  .......  .......    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        0.1
  Five-year carryback period for net operating         (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        0.2
   losses atrributable to farming..................
Commerce and Housing
  Financial institutions:
    Exemption of credit union income...............      1.1      1.1      1.2      1.3      1.3  .......  .......  .......  .......  .......        6.0
  Insurance companies:
    Exclusion of investment income on life               1.4      1.4      1.4      1.5      1.5     24.0     24.6     25.2     25.8     26.5      133.2
     insurance and annuity contracts...............
    Small life insurance company taxable income          0.1      0.1      0.1      0.1      0.1  .......  .......  .......  .......  .......        0.5
     adjustment....................................
    Special treatment of life insurance company          1.3      1.3      1.3      1.4      1.4  .......  .......  .......  .......  .......        6.8
     reserves......................................
    Deduction of unpaid property loss reserves for       1.4      1.4      1.4      1.5      1.5  .......  .......  .......  .......  .......        7.2
     property and casualty insurance companies.....
    Special deduction for Blue Cross and Blue            0.3      0.3      0.3      0.3      0.3  .......  .......  .......  .......  .......        1.5
     Shield companies..............................
  Housing:
    Deduction for mortgage interest on owner-        .......  .......  .......  .......  .......     69.9     72.6     76.5     80.5     85.5      384.9
     occupied residences...........................
    Deduction for property taxes on owner-occupied   .......  .......  .......  .......  .......     22.1     21.7     19.0     15.4     14.0       92.1
     residences....................................
    Exclusion of capital gains on sales of           .......  .......  .......  .......  .......     17.8     17.9     18.2     18.4     18.7       91.0
     principal residences..........................
    Exclusion of interest on State and local             0.3      0.3      0.3      0.3      0.3      0.7      0.8      0.8      0.8      0.8        5.3
     government bonds for owner-occupied housing...
    Exclusion of interest on State and local             0.1      0.1      0.1      0.1      0.1      0.2      0.2      0.2      0.2      0.2        1.1
     government bonds for rental housing...........
    Depreciation of rental housing in excess of          0.3      0.3      0.4      0.4      0.5      2.8      3.1      3.4      3.8      4.4       19.4
     alternative depreciation system...............
    Tax credit for low-income housing..............      2.9      3.0      3.2      3.3      3.4      1.2      1.3      1.4      1.4      1.5       22.5
    Tax credit for first-time homebuyers in the      .......  .......  .......  .......  .......    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)      (\1\)
     District of Columbia..........................
    Tax credit for rehabilitation of historic            0.4      0.4      0.4      0.4      0.4      0.1      0.1      0.1      0.1      0.1        2.5
     structures....................................
  Other business and commerce:
    Reduced rates of tax on long-term capital gains  .......  .......  .......  .......  .......     55.3     54.7     52.8     53.2     48.6      264.6
    Exclusion of capital gains at death............  .......  .......  .......  .......  .......     38.1     41.1     44.3     47.6     49.1      220.2
    Carryover basis of capital gains on gifts......  .......  .......  .......  .......  .......      4.5      4.7      5.0      5.3      5.6       25.1
    Deferral of gain on non-dealer installment           0.7      0.7      0.7      0.7      0.7      0.5      0.5      0.5      0.5      0.5        6.0
     sales.........................................
    Deferral of gain on like-kind exchanges........      1.4      1.4      1.5      1.5      1.5      0.5      0.5      0.5      0.5      0.5        9.8
    Deferral of gain on involuntary conversions      .......  .......  .......  .......  .......    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        0.1
     resulting from Presidentially-declared
     disasters.....................................
    Depreciation of buildings other than rental          1.5      1.4      1.1      0.9      1.2      0.9      0.9      0.6      0.2      0.3        9.1
     housing in excess of alternative depreciation
     system........................................
    Depreciation of equipment in excess of              39.3     36.2     19.1     10.3     14.4     10.5      9.2      4.2      1.6      2.7      147.5
     alternative depreciation system...............
    Expensing of depreciable business property.....     -0.1    (\3\)      0.1      0.2      0.2     -0.6     -0.2      0.5      0.8      0.7        1.5
    Amortization of business startup costs.........    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)      0.6      0.6      0.6      0.6      0.6        3.0
    Reduced rates on first $10,000,000 of corporate      4.4      4.6      4.8      4.9      5.1  .......  .......  .......  .......  .......       23.7
     taxable income................................
    Permanent exemption from imputed interest rules    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)      0.3      0.3      0.3      0.3      0.3        1.5
    Expensing of magazine circulation expenditures.    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        0.2
    Special rules for magazine, paperback book, and    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        0.1
     record returns................................
    Completed contract rules.......................      0.2      0.2      0.2      0.2      0.2    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        1.2
    Cash accounting, other than agriculture........    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)      0.5      0.5      0.5      0.5      0.5        2.5
    Exclusion of interest on State and local             0.1      0.1      0.1      0.1      0.1      0.3      0.3      0.3      0.3      0.3        2.0
     government small-issue industrial development
     bonds.........................................
    Exception from net operating loss limitations        0.8      0.6      0.6      0.6      0.6  .......  .......  .......  .......  .......        3.2
     for corporations in bankruptcy proceedings....
    Tax credit for employer-paid FICA taxes on tips      0.1      0.1      0.1      0.2      0.2      0.2      0.3      0.3      0.3      0.3        1.9
Transportation
  Deferral of tax on capital construction funds of       0.1      0.1      0.1      0.1      0.1  .......  .......  .......  .......  .......        0.5
   shipping companies..............................
  Exclusion of employer-paid transportation          .......  .......  .......  .......  .......      3.7      3.8      3.8      3.9      3.9       19.1
   benefits........................................
  Exclusion of interest on State and local             (\1\)    (\1\)    (\1\)    (\1\)    (\1\)      0.1      0.1      0.1      0.1      0.1        0.5
   government bonds for high-speed rail............
Community and Regional Development
  New York City Liberty Zone tax incentives........      0.4      0.2      0.5      0.7      0.6      0.4      0.3      0.4      0.5      0.3        4.4
  Empowerment zone tax incentives..................      0.3      0.3      0.3      0.4      0.4      0.3      0.3      0.4      0.4      0.4        3.5
  Renewal community tax incentives.................      0.1      0.1      0.2      0.2      0.3      0.3      0.3      0.4      0.4      0.4        2.7
  New markets tax credit...........................    (\1\)      0.1      0.2      0.2      0.3      0.1      0.1      0.2      0.3      0.4        2.0
  District of Columbia tax incentives..............    (\1\)      0.1      0.1      0.1      0.1      0.1      0.1      0.1      0.1      0.1        0.7
  Indian reservation tax incentives................      0.4      0.5      0.3     -0.1     -0.3      0.2      0.2      0.2    (\3\)     -0.1        1.3
  Expensing of environmental remediation costs           0.1    (\1\)    (\3\)    (\3\)    (\3\)      0.1      0.1    (\3\)    (\3\)    (\3\)        0.3
   (``Brownfields'')...............................
  Tax credit for rehabilitation of structures,         (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        0.1
   other than historic structures..................
  Exclusion of interest on State and local               0.2      0.2      0.2      0.2      0.2      0.5      0.6      0.6      0.6      0.6        3.9
   government bonds for private airports, docks,
   and mass-commuting facilities...................
Education, Training, Employment, and Social
 Services
  Education and training:
    Tax credits for tuition for post-secondary       .......  .......  .......  .......  .......      4.3      4.3      4.3      4.4      4.4       21.7
     education.....................................
    Deduction for interest on student loans........  .......  .......  .......  .......  .......      0.6      0.7      0.8      0.8      0.9        3.8
    Deduction for higher education expenses........  .......  .......  .......  .......  .......      2.1      2.7      2.9      0.7  .......        8.4
    Exclusion of earnings of trust accounts for      .......  .......  .......  .......  .......      0.4      0.5      0.6      0.7      0.8        3.0
     higher education (``education IRAs'').........
    Exclusion of interest on educational savings     .......  .......  .......  .......  .......    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        0.1
     bonds.........................................
    Deferral of tax on earnings of qualified State   .......  .......  .......  .......  .......      0.2      0.2      0.3      0.3      0.4        1.4
     tuition programs..............................
    Exclusion of scholarship and fellowship income.  .......  .......  .......  .......  .......      1.4      1.5      1.5      1.6      1.6        7.6
    Exclusion of employer-provided education         .......  .......  .......  .......  .......      0.7      0.8      0.8      0.9      0.9        4.1
     assistance benefits...........................
    Parental personal exemption for students age 19  .......  .......  .......  .......  .......      1.5      1.4      1.2      0.7      0.5        5.3
     to 23.........................................
    Exclusion of interest on State and local             0.1      0.1      0.1      0.1      0.1      0.3      0.3      0.3      0.3      0.3        1.8
     government student loan bonds.................
    Exclusion of interest on State and local             0.3      0.3      0.3      0.3      0.3      0.7      0.7      0.8      0.8      0.8        5.3
     government bonds for private nonprofit
     educational facilities 4......................
    Tax credit for holders of qualified zone           (\1\)      0.1      0.1      0.1      0.1  .......  .......  .......  .......  .......        0.4
     academy bonds.................................
    Deduction for charitable contributions to            1.0      1.1      1.1      1.1      1.2      6.2      6.4      6.6      6.8      7.0       38.3
     educational institutions......................
    Above the line deduction for teacher classroom   .......  .......  .......  .......  .......      0.2      0.1  .......  .......  .......        0.3
     expenses......................................
  Employment:
    Exclusion of employee meals and lodging (other   .......  .......  .......  .......  .......      0.9      0.9      0.9      0.9      0.9        4.5
     than military)................................
    Exclusion of benefits provided under cafeteria   .......  .......  .......  .......  .......     14.0     14.8     16.0     16.8     18.0       79.5
     plans 5.......................................
    Exclusion of housing allowances for ministers..  .......  .......  .......  .......  .......      0.4      0.5      0.5      0.5      0.5        2.4
    Exclusion of miscellaneous fringe benefits.....  .......  .......  .......  .......  .......      6.0      6.2      6.4      6.7      7.0       32.3
    Exclusion of employee awards...................  .......  .......  .......  .......  .......      0.1      0.1      0.2      0.2      0.2        0.8
    Exclusion of income earned by voluntary          .......  .......  .......  .......  .......      3.0      3.2      3.4      3.5      3.7       16.8
     employees' beneficiary associations...........
    Special tax provisions for employee stock            0.8      0.9      0.9      0.9      0.9      0.2      0.2      0.3      0.3      0.3        5.6
     ownership plans (``ESOPs'')...................
    Work opportunity tax credit....................      0.3      0.2      0.1    (\1\)    (\1\)      0.1    (\1\)    (\1\)    (\1\)    (\1\)        0.8
    Welfare-to-work tax credit.....................      0.1      0.1    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        0.3
    Deferral of taxation on spread on acquisition    .......  .......  .......  .......  .......      0.3      0.4      0.4      0.5      0.5        2.1
     of stock under incentive stock option plans
     and employee stock purchase plans \6\.........
  Social services:
    Tax credit for children under age 17 \7\.......  .......  .......  .......  .......  .......     27.1     26.9     30.1     31.7     31.0      146.8
    Tax credit for child and dependent care          .......  .......  .......  .......  .......      3.2      3.0      2.5      2.0      1.9       12.6
     expenses......................................
    Exclusion of employer-provided child care \8\..  .......  .......  .......  .......  .......      0.8      0.8      0.9      0.9      1.0        4.4
    Tax credit for employer-provided child care....      0.1      0.1      0.1      0.1      0.2    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        0.7
    Exclusion of certain foster care payments......  .......  .......  .......  .......  .......      0.6      0.6      0.7      0.7      0.8        3.4
    Adoption credit and employee adoption benefits   .......  .......  .......  .......  .......      0.2      0.3      0.4      0.4      0.4        1.7
     exclusion.....................................
    Deduction for charitable contributions, other        1.7      1.8      1.9      1.9      2.0     32.5     33.5     34.5     35.6     36.7      182.0
     than for education and health.................
    Tax credit for disabled access expenditures....    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)      0.1      0.1      0.1      0.1      0.1        0.4
Health
  Exclusion of employer contributions for health     .......  .......  .......  .......  .......     79.6     85.1     91.8     98.7    106.6      461.8
   care, health insurance premiums, and long-term
   care insurance premiums \9\.....................
  Exclusion of medical care and CHAMPUS/TRICARE      .......  .......  .......  .......  .......      1.8      1.8      1.8      1.9      1.9        9.1
   medical insurance for military dependents,
   retirees, and retiree dependents................
  Deduction for health insurance premiums and long-  .......  .......  .......  .......  .......      2.5      2.9      3.1      3.2      3.4       15.1
   term care insurance premiums by the self-
   employed........................................
  Deduction for medical expenses and long-term care  .......  .......  .......  .......  .......      5.9      6.1      6.3      6.5      6.9       31.6
   expenses........................................
  Exclusion of workers' compensation benefits        .......  .......  .......  .......  .......      3.8      3.9      4.0      4.1      4.1       20.0
   (medical benefits)..............................
  Medical savings accounts.........................  .......  .......  .......  .......  .......    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        0.1
  Exclusion of interest on State and local               0.4      0.4      0.4      0.4      0.4      1.1      1.1      1.1      1.1      1.1        7.7
   government bonds for private nonprofit hospital
   facilities......................................
  Deduction for charitable contributions to health       0.9      0.9      1.0      1.0      1.0      4.2      4.4      4.5      4.6      4.8       27.4
   organizations...................................
  Tax credit for orphan drug research..............      0.2      0.2      0.2      0.2      0.2  .......  .......  .......  .......  .......        1.0
  Tax credit for purchase of health insurance by     .......  .......  .......  .......  .......      0.3      0.4      0.5      0.5      0.5        2.1
   certain displaced persons.......................
Medicare
  Exclusion of untaxed Medicare benefits:
    Hospital insurance.............................  .......  .......  .......  .......  .......     13.9     15.1     16.3     17.5     18.7       81.5
    Supplementary medical insurance................  .......  .......  .......  .......  .......      9.1      9.7     10.4     11.3     12.4       52.9
Income Security
  Exclusion of workers' compensation benefits        .......  .......  .......  .......  .......      4.7      4.8      4.9      5.0      5.3       24.7
   (disability and survivors payments).............
  Exclusion of damages on account of personal        .......  .......  .......  .......  .......      1.4      1.4      1.4      1.4      1.7        7.1
   physical injuries or physical sickness..........
  Exclusion of special benefits for disabled coal    .......  .......  .......  .......  .......      0.1      0.1      0.1      0.1      0.1        0.3
   miners..........................................
  Exclusion of cash public assistance benefits.....  .......  .......  .......  .......  .......      3.0      3.2      3.3      3.5      3.6       16.6
  Net exclusion of pension contributions and
   earnings:
    Employer plans.................................  .......  .......  .......  .......  .......     83.5     94.7     99.7    104.9    110.3      493.1
    Individual retirement plans....................  .......  .......  .......  .......  .......     10.4     13.7     16.1     17.8     19.3       77.3
    Keogh plans....................................  .......  .......  .......  .......  .......      5.7      5.8      6.0      6.4      6.7       30.5
  Tax credit for certain individuals for elective    .......  .......  .......  .......  .......      1.6      1.5      1.4      1.3      0.4        6.3
   deferrals and IRA contributions.................
  Tax credit for new retirement plan expenses of       (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        0.1
   small businesses................................
  Exclusion of other employee benefits:
    Premiums on group term life insurance..........  .......  .......  .......  .......  .......      2.4      2.5      2.6      2.7      2.7       12.6
    Premiums on accident and disability insurance..  .......  .......  .......  .......  .......      2.3      2.4      2.5      2.7      2.8       12.7
  Additional standard deduction for the blind and    .......  .......  .......  .......  .......      2.0      2.1      2.2      2.3      2.2       10.7
   the elderly.....................................
  Tax credit for the elderly and disabled..........  .......  .......  .......  .......  .......    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        0.1
  Deduction for casualty and theft losses..........  .......  .......  .......  .......  .......      0.2      0.2      0.2      0.2      0.2        1.1
  Earned income credit (``EIC'') \7\...............  .......  .......  .......  .......  .......     34.1     34.6     35.9     36.8     37.3      178.8
Social Security and Railroad Retirement
  Exclusion of untaxed Social Security and railroad  .......  .......  .......  .......  .......     21.6     22.2     22.8     23.4     24.2      114.2
   retirement benefits.............................
Veterans' Benefits and Services
  Exclusion of veterans' disability compensation...  .......  .......  .......  .......  .......      2.6      2.7      2.8      2.8      2.8       13.7
  Exclusion of veterans' pensions..................  .......  .......  .......  .......  .......      0.1      0.1      0.1      0.1      0.1        0.6
  Exclusion of veterans' readjustment benefits.....  .......  .......  .......  .......  .......      0.1      0.1      0.1      0.1      0.1        0.6
  Exclusion of interest on State and local             (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)    (\1\)        0.2
   government bonds for veterans' housing..........
General Purpose Fiscal Assistance
  Exclusion of interest on public purpose State and      6.6      6.7      6.8      6.9      7.0     16.9     17.3     17.6     17.9     18.2      121.6
   local government debt...........................
  Deduction of nonbusiness State and local           .......  .......  .......  .......  .......     50.9     50.4     46.7     39.0     36.4      223.5
   government income and personal property taxes...
  Tax credit for Puerto Rico and possession income,      1.8      1.6      1.4      0.4  .......  .......  .......  .......  .......  .......        5.2
   and Puerto Rico economic activity...............
Interest
  Deferral of interest on savings bonds............  .......  .......  .......  .......  .......      1.6      1.6      1.6      1.6      1.6        8.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
\1\ Positive tax expenditure of less than $50 million.
\2\ In addition, the exemption from excise tax for alcohol fuels results in a reduction in excise tax receipts, net of income tax effect, of $0.7
  billion in fiscal year 2003, and $0.8 billion per year in fiscal years 2004 through 2007.
\3\ Negative tax expenditure of less than $50 million.
\4\ Estimate includes tax-exempt bonds for qualified educational facilities.
\5\ Estimate includes amounts of employer-provided health insurance purchased through cafeteria plans and employer-provided child care  purchased
  through dependent care flexible spending accounts. These amounts are also included in other line items in this table.
\6\ Tax expenditure estimate does not include offsetting denial of corporate deduction for qualified stock option compensation.
\7\ The amount of refundable child tax credit and earned income tax credit used to offset taxes other than income tax or paid out as refunds is: $38.1
  billion in 2003, $37.9 billion in 2004, $38.5 billion in 2005, $41.7 billion in 2006, and $42.3 billion in 2007.
\8\ Estimate includes employer-provided child care purchased through dependent care flexible spending accounts.
\9\ Estimate includes employer-provided health insurance purchased through cafeteria plans.
 Note.--Details may not add to totals due to rounding.
 Source: Joint Committee on Taxation.


            Table 2.--Distribution by Income Class of All Returns, Taxable Returns, Itemized Returns,
                                  and Tax Liability for Calendar Year 2002 \1\
                          [Money amounts in millions of dollars, returns in thousands]
----------------------------------------------------------------------------------------------------------------
                                                                   Taxable          Itemized
        Income class [thousands] \2\          All returns \3\      returns          returns       Tax liability
----------------------------------------------------------------------------------------------------------------
Below $10...................................           21,483            1,061              223          -$6,706
$10 to $20..................................           27,714            9,343            1,069          -10,952
$20 to $30..................................           20,439           10,443            2,132            3,442
$30 to $40..................................           16,654           12,487            3,182           21,603
$40 to $50..................................           12,068           10,461            3,598           29,159
$50 to $75..................................           21,869           21,008            9,835           94,031
$75 to $100.................................           12,669           12,566            8,736           95,316
$100 to $200................................           13,366           13,324           11,718          220,062
$200 and over...............................            3,376            3,370            3,216          419,596
                                             -------------------------------------------------------------------
      Total.................................          149,638           94,061           43,708         $865,551
----------------------------------------------------------------------------------------------------------------
\1\ Tax law as in effect on January 1, 2002, is applied to the 2002 level and sources of income and their
  distribution among taxpayers.
\2\ The income concept used to place tax returns into classes is adjusted gross income (``AGI'') plus: (a) tax-
  exempt interest, (b) employer  contributions for health plans and life insurance, (c) employer share of FICA
  tax, (d) workers' compensation, (e) nontaxable Social Security  benefits, (f) insurance value of Medicare
  benefits, (g) alternative minimum tax preference items, and (h) excluded income of U.S. citizens living
  abroad.
\3\ Includes filing and nonfiling units. Filing units include all taxable and nontaxable returns. Nonfiling
  units include individuals with  income that is exempt from Federal income taxation (e.g., transfer payments,
  interest from tax-exempt bonds, etc.). Excludes individuals  who are dependents of other taxpayers and
  taxpayers with negative income.
 Note.--Details may not add to totals due to rounding.
 Source: Joint Committee on Taxation.


               Table 3.--Distribution by Income Class of Selected Individual Tax Expenditure Items
                                           for Calendar Year 2002 \1\
                          [Money amounts in millions of dollars, returns in thousands]
----------------------------------------------------------------------------------------------------------------
                                                      Medical deduction             Real estate tax deduction
        Income class [thousands] \2\         -------------------------------------------------------------------
                                                  Returns           Amount          Returns           Amount
----------------------------------------------------------------------------------------------------------------
Below $10...................................               56               $5               51               $2
$10 to $20..................................              714              232            1,166              117
$20 to $30..................................              845              405            2,165              341
$30 to $40..................................              766              466            2,900              597
$40 to $50..................................              699              619            3,377              947
$50 to $75..................................            1,237            1,545            9,252            3,519
$75 to $100.................................              511              958            6,983            4,275
$100 to $200................................              306            1,203            7,255            6,654
$200 and over...............................               32              433            2,068            4,786
                                             -------------------------------------------------------------------
      Total.................................            5,165           $5,867           35,217          $21,238
----------------------------------------------------------------------------------------------------------------
Footnotes at end of table.


               Table 3.--Distribution by Income Class of Selected Individual Tax Expenditure Items
                                      for Calendar Year 2002 \1\--Continued
                          [Money amounts in millions of dollars, returns in thousands]
----------------------------------------------------------------------------------------------------------------
                                                 State and local income and         Charitable contributions
                                               personal property tax deduction              deduction
        Income class [thousands] \2\         -------------------------------------------------------------------
                                                  Returns           Amount          Returns           Amount
----------------------------------------------------------------------------------------------------------------
Below $10...................................               50               $2               59               $2
$10 to $20..................................            1,183               66            1,257              122
$20 to $30..................................            2,435              241            2,498              365
$30 to $40..................................            3,197              584            3,171              695
$40 to $50..................................            3,712            1,176            3,645            1,066
$50 to $75..................................            9,723            4,871            9,705            4,058
$75 to $100.................................            7,007            6,744            7,219            5,251
$100 to $200................................            7,378           12,369            7,890            8,913
$200 and over...............................            2,247           22,841            2,592           19,959
                                             -------------------------------------------------------------------
      Total.................................           36,933          $48,894           38,035          $40,428
----------------------------------------------------------------------------------------------------------------
 Footnotes at end of table.


               Table 3.--Distribution by Income Class of Selected Individual Tax Expenditure Items
                                      for Calendar Year 2002 \1\--Continued
                          [Money amounts in millions of dollars, returns in thousands]
----------------------------------------------------------------------------------------------------------------
                                                      Child care credit             Earned income credit \3\
        Income class [thousands] \2\         -------------------------------------------------------------------
                                                  Returns           Amount          Returns           Amount
----------------------------------------------------------------------------------------------------------------
Below $10...................................                1            (\4\)            5,370           $6,760
$10 to $20..................................               68              $20            5,868           15,053
$20 to $30..................................              429              222            4,434            9,254
$30 to $40..................................              583              348            2,520            2,703
$40 to $50..................................              638              364              352              212
$50 to $75..................................            1,508              745               16               21
$75 to $100.................................            1,163              604  ...............  ...............
$100 to $200................................            1,500              806  ...............  ...............
$200 and over...............................              227              128  ...............  ...............
                                             -------------------------------------------------------------------
      Total.................................            6,117           $3,236           18,560         $34,002
----------------------------------------------------------------------------------------------------------------
 Footnotes at end of table.


                                                                                               Table 3.--Distribution by Income Class of Selected Individual Tax Expenditure Items
                                                                                                                      for Calendar Year 2002 \1\--Continued
                                                                                                          [Money amounts in millions of dollars, returns in thousands]
--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
                                                      Untaxed Social Security and                                                                                                         Child Tax Credit \3\
                                                     Railroad Retirement benefits
           Income class [thousands] \2\           ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
                                                       Returns           Amount                                                 Returns                                                                                        Amount
--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Below $10........................................               38               $3                                                      52                                                                                            $22
$10 to $20.......................................            2,688              594                                                   3,256                                                                                          1,203
$20 to $30.......................................            5,653            4,062                                                   4,158                                                                                          3,147
$30 to $40.......................................            3,925            5,288                                                   3,671                                                                                          3,399
$40 to $50.......................................            2,670            3,479                                                   3,247                                                                                          3,153
$50 to $75.......................................            4,740            5,826                                                   7,149                                                                                          7,216
$75 to $100......................................            2,096            1,042                                                   4,973                                                                                          5,178
$100 to $200.....................................            1,649              400                                                   4,204                                                                                          3,857
$200 and over....................................              496              164                                                       1                                                                                             -1
                                                  ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
      Total......................................           23,955          $20,858                                                  30,709                                                                                        $27,176
--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Footnotes at end of table.


               Table 3.--Distribution by Income Class of Selected Individual Tax Expenditure Items
                                      for Calendar Year 2002 \1\--Continued
                          [Money amounts in millions of dollars, returns in thousands]
----------------------------------------------------------------------------------------------------------------
                                                                                   Mortgage interest deduction
                         Income class [thousands] \2\                          ---------------------------------
                                                                                    Returns           Amount
----------------------------------------------------------------------------------------------------------------
Below $10.....................................................................               67              $13
$10 to $20....................................................................            1,076              239
$20 to $30....................................................................            1,938              817
$30 to $40....................................................................            2,759            1,646
$40 to $50....................................................................            3,233            2,930
$50 to $75....................................................................            8,879           10,704
$75 to $100...................................................................            6,666           14,070
$100 to $200..................................................................            6,976           21,945
$200 and over.................................................................            2,110           14,570
                                                                               ---------------------------------
      Total...................................................................           33,704          $66,934
----------------------------------------------------------------------------------------------------------------
Footnotes for Table 3:
\1\ Excludes individuals who are dependents of other taxpayers and taxpayers with negative income.
\2\ The income concept used to place tax returns into classes is adjusted gross income (``AGI'') plus: (a) tax-
  exempt interest, (b) employer  contributions for health plans and life insurance, (c) employer share of FICA
  tax, (d) workers' compensation, (e) nontaxable Social Security  benefits, (f) insurance value of Medicare
  benefits, (g) alternative minimum tax preference items, and (h) excluded income of U.S. citizens  living
  abroad.
\3\ Includes the refundable portion.
\4\ Less than $500,000.
 Note.--Details may not add to totals due to rounding.
 Source: Joint Committee on Taxation.

                                
