WASHINGTON (AP) _ The government is owed nearly $50 billion in unpaid payroll taxes and has little chance of collecting it all, a congressional audit has found. Poor record-keeping by the Internal Revenue Service is partly responsible.

IRS Commissioner Charles Rossotti said the agency would use the audit to make ``what near-term improvements we can.''

More than 1.8 million businesses owed $49 billion in cumulative unpaid payroll taxes as of Sept. 30, 1998, according to the General Accounting Office audit released Monday by the House Government Reform Committee's government management panel. The sum includes about $19 billion in unpaid taxes and $30 billion in penalties and interest.

The $49 billion figure also represents just under one-fourth _ 22 percent _ of the $222 billion in taxes owed the IRS as of September 1998, the audit said.

The agency also has levied $15 billion in additional penalties against 185,000 people for withholding but not forwarding the payroll taxes _ which help pay for Social Security and Medicare benefits _ to the federal Treasury.

At the same time, more than 18,000 people in this group received federal benefits worth $212 million, including Social Security and retirement payments, despite their $2 billion in payroll tax debt, the audit found. Others received vendor payments and loans. Federal law does not bar businesses or individuals from collecting federal payments or loans while they owe payroll taxes.

Kutz said it was unlikely that all of the outstanding payroll tax payments would be recovered. Many of the businesses are defunct or do not have the money to pay or the IRS cannot find them, IRS records reviewed for the audit show.

Most of the offenders were small businesses in labor-intensive industries with few assets, such as construction companies and restaurants, Kutz said.

He estimated no more than 9 cents on the dollar eventually would be collected.

Several factors contribute to the problem, including technological and other operational weaknesses at the IRS, Kutz said. The agency has no assurance that its records are accurate because it keeps separate databases for businesses and individuals on systems that cannot communicate with each other.

Taxpayer education and programs to highlight delinquency problems before they become serious also have been ineffective.

State and federal law also can hinder the IRS' ability to collect, and the agency's criminal division will not prosecute taxpayers who fail to pay payroll taxes unless fraud is clearly evident, the audit said.

Although Rossotti said the IRS would use the report to make improvements, he cautioned subcommittee members against looking for a quick fix.

``It would be misleading everyone to believe this problem can be solved by anything we could do short of revamping this process,'' he said.

The 102,000-employee agency is implementing changes required by a 1998 restructuring law. It also plans next summer to begin withholding up to 15 percent of a delinquent taxpayer's federal benefits, as authorized by separate legislation.