Jay A. Soled (Rutgers; Google Scholar), The Gift Tax and the Tax Gap, 182 Tax Notes Fed. 1047 (Feb. 5, 2024):

There is ample evidence that the nation’s gift tax revenue is ravaged by taxpayer noncompliance, thereby enlarging the overall federal tax gap. In a nutshell, taxpayers often make gifts that exceed the gift tax annual exclusion, yet they fail to report this information to the IRS, and the agency lacks the resources and ability to identify those derelictions. The result is that the nation’s coffers suffer.

To level the information playing field between taxpayers and the IRS, this analysis champions two simple reform measures that could narrow the tax gap, yielding billions of dollars in additional tax revenue without raising taxes.