HELENA -- For the second straight legislative session, the Montana Revenue Department has run into a buzz saw of opposition to its bills to crack down on out-of-state businesses and individuals it believes are skirting their tax obligations here.

While the agency's bills are passing the Democrat-led Senate on party-line votes, few are emerging from the Republican-controlled House. Lobbyists representing a variety of business groups, such as the Montana Chamber of Commerce, Taxpayers Association and Society of Certified Public Accountants, have lined up against many bills.

"We're baffled,'' Revenue Director Dan Bucks said. "We don't know why legislators would defend nonresidents and out-of-state corporations who don't pay the taxes that they owe here. It's a great unanswered question.''

If all these bills pass and the Revenue Department receives the money it seeks to hire nearly 100 new employees for an enhanced auditing and collection effort and to meet a rapidly expanding workload, Bucks figures the state could collect $64 million in additional net revenue the next two years and $85 million the following two years.

If Bucks can bring in this revenue, Gov. Brian Schweitzer vowed to give it back to Montanans as more tax relief.

Schweitzer called Bucks, executive director of the Multistate Tax Commission for 17 years, "probably the most professional revenue director in (state) history with the best resume.''

When he appointed Bucks after the 2004 election, Schweitzer said he told the new revenue director his "No. 1 task is to collect dollars that were owed to us that we're not collecting.''

Bucks has taken up that assignment in earnest and, critics say, with a vengeance.

Mary Whittinghill, president of the Montana Taxpayers Association, which has opposed some bills, said Bucks already has sufficent tools to go after tax scofflaws. A better approach, she said, is to give the department the tools to identify whether a problem exists with out-of-state tax compliance. She doubts whether the problem is as serious as Bucks claims.

"We think that their estimates (of anticipated revenue) in their fiscal notes are inflated,'' she said. "It's too much, too fast.''

Jane Egan, executive director of the Montana Society of Certified Public Accountants, said the group supports many concepts the department has proposed to increase tax compliance, "but we feel that a lot of the bills they have put forth are too much.''

"They're too broad,'' she said. "We fear they will pull in innocent Montana citizens when they're actually trying to get the out-of-state people.''

The society would like to see the department educate taxpayers more and "start in small steps,'' she said.

Webb Brown, president of the Montana Chamber of Commerce, agreed.

"We're sitting on a projected $1 billion surplus,'' Brown said. "Yet they're saying, 'We're still not squeezing the fruit hard enough.' ''

Asked why the chamber would oppose making sure out-of-staters pay their Montana taxes, Brown said, "We absolutely believe that everyone should pay their fair share. Some of this (legislation) is new theory and a new reach of the law to classify or call legitimate tax planning measures as either abusive or illegal.''

House Taxation Chairman Bob Lake, R-Hamilton, said there are no limitations on the Revenue Department's existing authority to track down tax cheats, and Republicans fully support that.

"But other parts of the governor's bills will have a far greater impact on honest taxpayers than on noncompliers,'' Lake wrote in a letter to newspaper editors. "Many of the governor's tax proposals are designed to create a bloated Department of Revenue, which is the state version of the Internal Revenue Service.''

In response, Bucks dismissed criticism that he is seeking too much, too quickly.

"We're asking for what we think is necessary to protect honest Montana taxpayers who are paying their fair share of taxes,'' the director said. "We're asking for only enough to protect Montana businesses from unfair competition, especially out-of-state businesses that don't pay the right amount of taxes.''

These are not new ideas, he said. Each of the agency's bills has been "tried and tested'' by at least one other state or by the Internal Revenue Service.

When he testifies before committees, Bucks talks with great pride about how virtually all Montana retirees and wage and salary earners fully and voluntarily comply with tax laws and so do Montana residents selling property. But he says that rate falls to 30 percent for nonresidents selling Montana property and owing taxes and to 21 percent for nonresidents who receive oil and gas royalty payments here.

"The Department of Revenue exists in large part to ensure justice for all taxpayers,'' Bucks said.

If anything, Bucks said the department's revenue projections for these proposed bills err on the low side. In 2005, the agency launched an enhanced effort to collect back taxes. Bucks had projected it would reap three times as much money as it cost, but it has returned 11 times as much.

Senate Taxation Chairman Jim Elliott, D-Trout Creek, who is sponsoring many of the bills, said he believes Republicans are voting against these bills because they view "departments of revenue, and not just this one, as capricious and arbitrary.''

Elliott said he sees the Revenue Department differently, saying it ''collects the revenue to provide the services that we demand and enjoy as citizens.''

"Dan Bucks is a very passionate director, but he sometimes approaches zealotry in his advocacy for the common person in his quest to make sure that Montanans aren't treated like suckers by out-of-state taxpayers,'' Elliott said. "Some people are uncomfortable in dealing with a person who has that intensity of belief and the knowledge and expertise to back it up.''