Internal Revenue Service: Physical Security Over Taxpayer Receipts and
Data Needs Improvement (Letter Report, 11/30/98, GAO/AIMD-99-15).

Pursuant to a legislative requirement, GAO reviewed the Internal Revenue
Service's (IRS) physical controls over receipts and taxpayer data.

GAO noted that: (1) IRS' controls over receipts and taxpayer data do not
adequately reduce the vulnerability of the federal government and
taxpayers to loss from theft; (2) this condition existed because of the
length of time required to conduct background investigations, delays in
receiving results of fingerprint checks, and processing demands which
required the hiring of thousands of employees during the peak filing
season; (3) placing new hires in sensitive positions prior to, at a
minimum, receiving the results of fingerprint check increases the
vulnerability of receipts and taxpayer data to theft; (4) in fact, of
the 80 thefts IRS investigated at service centers from January 1995 to
July 1997, 12 were committed by individuals who had previous arrest
records that were not identified prior to their employment; (5) GAO also
noted weaknesses in the physical controls over service center and
district office receipts; (6) while service center receipts are required
to be processed only by authorized individuals in the Receipt and
Control Branch, which is a restricted access area, numerous receipts
were found in unrestricted areas accessible to other IRS employees and
to non-employees not authorized to handle receipts; (7) receipts
particularly vulnerable to theft also were not adequately secured; (8)
while it is important to adequately protect cash and checks received at
IRS facilities, it is similarly essential to ensure that these receipts
are properly protected during transport to depository institutions; (9)
GAO found that single, unarmed couriers in ordinary civilian vehicles
were used to transport IRS deposits totalling hundreds of millions of
dollars to the depository institutions during the peak filing season;
(10) the theft of one peak season deposit could place a significant
administrative burden on IRS to contact taxpayers and initiate stop
payment orders on tens of thousands of checks; (11) although receipts
and taxpayer information will always be vulnerable to theft, IRS has a
responsibility to protect the government and taxpayers from such losses;
(12) many of the actions GAO is recommending to minimize these
vulnerabilities and thus better protect taxpayer receipts and data would
not result in significant costs, and several other actions GAO is
recommending are already required by IRS policy or are currently under
consideration by IRS management; and (13) IRS has prepared two
corrective action plans to reduce its vulnerability to theft or loss of
receipts and taxpayer data.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  AIMD-99-15
     TITLE:  Internal Revenue Service: Physical Security Over Taxpayer 
             Receipts and Data Needs Improvement
      DATE:  11/30/98
   SUBJECT:  Tax administration systems
             Personnel management
             Internal controls
             Tax refunds
             Tax returns
             Fraud
             Larceny
             Federal employees
             Check disbursement or control
             Tax information confidentiality
IDENTIFIER:  FBI Integrated Automated Fingerprint Identification System
             
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Cover
================================================================ COVER


Report to the Commissioner of Internal Revenue

November 1998

INTERNAL REVENUE SERVICE -
PHYSICAL SECURITY OVER TAXPAYER
RECEIPTS AND DATA NEEDS
IMPROVEMENT

GAO/AIMD-99-15

IRS Physical Security

(919282)


Abbreviations
=============================================================== ABBREV

  FBI - x
  IRM - x
  IRS - x
  OPM - x
  PSC - x

Letter
=============================================================== LETTER


B-280960

November 30, 1998

The Honorable Charles O.  Rossotti
Commissioner of Internal Revenue

Dear Mr.  Rossotti,

This letter presents the results of our review of the Internal
Revenue Service's (IRS) physical controls over receipts and taxpayer
data.  As reported in our audit of IRS' fiscal year 1997 custodial
financial statements\1 and in subsequent congressional hearings on
IRS financial management issues,\2 IRS' internal controls at service
centers were not adequate to sufficiently ensure that cash and checks
received from taxpayers were properly credited to taxpayers' accounts
and deposited to the Department of the Treasury general fund.  We
further reported that these control weaknesses and inherent
vulnerabilities expose IRS and taxpayers to losses. 

To follow up on these weaknesses and to assess physical security
conditions at IRS during the peak filing season, we observed physical
controls over receipts and taxpayer data at service centers and
district offices in April 1998 as part of our ongoing audit of IRS'
fiscal year 1998 financial statements.  This report discusses
additional internal control weaknesses over the safeguarding of
receipts and taxpayer data that we identified in April 1998 and
provides our recommendations for improvement. 


--------------------
\1 Financial Audit:  Examination of IRS' Fiscal Year 1997 Custodial
Financial Statements (GAO/AIMD-98-77, February 26, 1998). 

\2 Internal Revenue Service:  Remaining Challenges to Achieve Lasting
Financial Management Improvements (GAO/T-AIMD/GGD-98-139, April 15,
1998). 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

IRS' controls over receipts and taxpayer data do not adequately
reduce the vulnerability of the federal government and taxpayers to
loss from theft.  For example, employees were hired and worked in
positions requiring the handling of cash, checks, or sensitive
taxpayer information before IRS received the results of these
employees' required background and/or fingerprint checks.  This
condition existed because of the length of time required to conduct
background investigations, delays in receiving results of fingerprint
checks, and processing demands which required the hiring of thousands
of employees during the peak filing season.  Placing new hires in
sensitive positions prior to, at a minimum, receiving the results of
fingerprint checks increases the vulnerability of receipts and
taxpayer data to theft.  In fact, of the 80 thefts IRS investigated
at service centers from January 1995 to July 1997, 12 (15 percent)
were committed by individuals who had previous arrest records or
convictions that were not identified prior to their employment and
thus may have influenced IRS' decision on whether to hire these
individuals. 

We also noted weaknesses in the physical controls over service center
and district office receipts.  While service center receipts are
required to be processed only by authorized individuals in the
Receipt and Control Branch, which is a restricted access area,
numerous receipts were found in unrestricted areas accessible to
other IRS employees and to non-employees not authorized to handle
receipts.  For example, at one service center receipts and returns
were stored in an uncontrolled hallway that individuals can enter
unchallenged from an adjoining fitness center and other areas of the
service center.  Receipts particularly vulnerable to theft, such as
returned refund checks, also were not adequately secured. 

While it is important to adequately protect cash and checks received
at IRS facilities, it is similarly essential to ensure that these
receipts are properly protected during transport to depository
institutions.  We found that single, unarmed couriers in ordinary
civilian vehicles were used to transport IRS deposits totaling
hundreds of millions of dollars to the depository institutions during
the peak filing season.  In fact, one courier left a deposit totaling
over $200 million unattended in an open vehicle while he returned to
the service center.  At one district office, IRS relied upon a
bicycle messenger to deliver daily deposits ranging from over $1
million during the nonpeak season to more than $100 million during
the peak season.  Because of the magnitude of IRS' deposits and the
sensitivity of taxpayer information contained on the checks, IRS'
current courier practice may be inadequate.  The theft of one peak
season deposit could place a significant administrative burden on IRS
to contact taxpayers and initiate stop payment orders on tens of
thousands of checks.  In addition, many taxpayers could suffer from
(1) damages if their stolen checks were used for check cloning
operations or (2) identity fraud since checks processed by IRS
contain not only bank account numbers, names, addresses, and taxpayer
signatures, but also encoded social security numbers. 

Although receipts and taxpayer information will always be vulnerable
to theft, IRS has a responsibility to protect the government and
taxpayers from such losses.  Many of the actions we are recommending
to minimize these vulnerabilities and thus better protect taxpayer
receipts and data would not result in significant costs, and several
other actions we are recommending are already required by IRS policy
or are currently under consideration by IRS management.  In fact, IRS
has prepared two corrective action plans to reduce its vulnerability
to theft or loss of receipts and taxpayer data.  IRS' Summary Action
Plan:  Protection of Monetary Instruments, dated May 20, 1998, lists
IRS' proposed actions for correcting internal control weaknesses
recently identified by internal auditors and by IRS' Office of
Systems Standards and Evaluation.  This document lists physical
security weaknesses identified by IRS and IRS' plans to address these
problems.  On June 4, 1998, IRS also issued a plan proposing a series
of specific actions to address control deficiencies related to
recruitment, background, and security investigations.  While these
two plans begin to address some of the weaknesses we identified, they
do not address several issues identified in this report.  For
example, the action plans do not address internal control weaknesses
at district offices or courier-related issues. 


   BACKGROUND
------------------------------------------------------------ Letter :2

In fiscal year 1997, IRS collected more than $1.6 trillion in tax
revenue.  Most of this revenue was collected by intermediaries, such
as financial depository institutions, and transferred directly to the
Treasury general fund.  However, the remainder--estimated at over
$100 billion in fiscal year 1997--was collected directly by IRS
through its many service centers and district offices.  Receipts IRS
collected directly consist primarily of cash and checks mailed to IRS
service centers with accompanying tax returns or payment vouchers and
payments made in person at one of the service centers or district
offices. 

While adequate physical safeguards over receipts should exist
throughout the year, it is especially important during the peak
filing season.  Each year, during the weeks before and immediately
after April 15, an IRS service center may receive and process daily
over 100,000 pieces of mail containing returns, receipts, or both. 
The dollar value of receipts each service center processes increases
to hundreds of millions of dollars a day during this time period.  In
addition, the number of staff increases significantly to handle and
process the additional volume.  For example, IRS hired over 20,000
seasonal employees nationwide for the 1998 filing season.  The
increased number of seasonal staff IRS employs to handle and process
this large volume of receipts and returns increases IRS'
vulnerability to theft. 

In addition to adequately safeguarding taxpayer receipts, it is
equally important for IRS to protect sensitive taxpayer data.  Tax
returns, schedules, and supporting documentation contain sensitive
identifying information such as name, address, social security
number, and details on the taxpayer's financial holdings.  Although
none of the financial crimes and identity fraud incidents we noted in
our previous report on identity fraud\3 were reported as being linked
to data stolen from IRS, sensitive information similar to that
processed by IRS has been used to commit such crimes nationwide. 
Commonly reported financial crimes and identity fraud include using
someone's personal information to fraudulently establish credit, run
up debt, or take over and deplete existing financial accounts. 
According to a Secret Service official, identified losses to
victimized individuals and institutions due to financial crimes
involving identity fraud increased from $442 million in fiscal year
1995 to $745 million in fiscal year 1997. 

IRS has also suffered losses due to various financial crime schemes. 
Between October 1995 and September 1997, IRS closed investigations on
22 cases involving theft of receipts at its district offices.\4 In
addition, between January 1995 and July 1997, IRS investigated 80
thefts of receipts totaling $5.3 million that occurred at its service
centers.  Of this amount, $4.6 million was attributable to one
individual who stole not only checks but also original tax returns. 
This individual sent the checks to members of an organized crime ring
in New York, who then altered or in some cases, "cloned"\5 the checks
for subsequent negotiation.  For example, one taxpayer's check was
cloned by the perpetrators into multiple smaller checks and
negotiated in England and Germany.  The cloning scheme was discovered
when the taxpayer's accountants noticed that the check written to IRS
was never cashed and that there were multiple additional checks
cashed for amounts for which they had no supporting documentation. 

Financial crimes and identity fraud committed through the theft of
receipts and tax return data can cause damage to many parties.  Banks
suffer financial loss when held accountable for damages resulting
from cloned checks.  The federal government may suffer losses in
cases involving IRS' failure to safeguard receipts and taxpayer data. 
Taxpayers can suffer injury to their reputations when credit is
fraudulently established and debts incurred in their names.  Bad
credit could in turn lead to difficulties in obtaining loans or jobs
and require a lengthy and expensive process to clear one's personal
records. 

While IRS inspectors have identified thefts of receipts and taxpayer
data, the true magnitude of such crimes that have occurred within IRS
will likely never be known.  An IRS inspector stated that the $5.3
million of investigated thefts at service centers is understated for
several reasons.  For example, during investigations, prosecuted
individuals confessed that they had stole other checks but could not
remember the full amount.  With the weaknesses and vulnerabilities
identified, there are likely many thefts that have gone undetected. 
Furthermore, although IRS has identified instances of original tax
returns stolen from service centers, the extent to which criminals
have taken advantage of stolen taxpayer information is less
measurable and thus largely unknown.  However, the potential for
using such data to commit identity fraud is great. 

Instances of financial crimes committed at IRS and their possible
consequences demonstrate the importance of establishing and
maintaining adequate physical controls over receipts and taxpayer
data.  We recognize that due to the high volume and sensitive nature
of IRS' activities, particularly during the peak filing season, no
system of internal control can eliminate the vulnerability of
receipts and sensitive taxpayer information to theft.  However, a
sound system of internal control should minimize the extent of this
vulnerability to ensure that the government and taxpayers are not
unduly exposed to loss of funds and misuse of taxpayer data, both of
which could undermine the public's trust in IRS' ability to safeguard
taxpayer funds and personal information. 


--------------------
\3 Identity Fraud:  Information on Prevalence, Cost, and Internet
Impact is Limited (GAO/GGD-98-100BR, May 1, 1998). 

\4 These thefts occurred in district offices and other post of duty
sites which fall under the responsibility of district directors. 

\5 Once a perpetrator obtains information, such as the bank and
account number, from a valid check, that information can be used to
"clone" or duplicate the original check into multiple fraudulent
blank checks.  These blank checks can then be made out to different
payees, the signature forged, and the checks deposited in the
perpetrators' accounts. 


   OBJECTIVES, SCOPE, AND
   METHODOLOGY
------------------------------------------------------------ Letter :3

The objectives of our review were to (1) follow-up on cash receipt
weaknesses identified in our audit of IRS' fiscal year 1997 Custodial
financial statements, and (2) observe operations during the peak
filing season as part of our fiscal year 1998 financial statement
audit.  We conducted our visits from April 20 through April 23, 1998,
at the Atlanta, Georgia, Austin, Texas, Ogden, Utah, and
Philadelphia, Pennsylvania, service centers.  These service centers
were selected based on the dollar amount of receipts processed during
fiscal year 1997 and on the dollar amount of reported thefts that
occurred between January 1995 and July 1997. 

We also conducted observation work at the Los Angeles, Northern
California, and North Texas district offices.  Two of these three
district offices were selected because they had teller units
responsible for making deposits of walk-in payments to the banks via
courier.  We also selected one district office that did not have a
teller unit and therefore sent all receipts, along with tax returns,
to a service center to be processed. 

We conducted observations of the activities and the physical controls
over the processing of receipts and tax returns at these service
centers and district offices, and had limited discussions with IRS
personnel at these sites.  As agreed with IRS' Chief Financial
Officer, we limited our inquiry of IRS employees during these visits
so we would not hinder operations during the peak filing season. 
However, we subsequently followed-up with IRS service center and
national office personnel to obtain clarification and further
explanation of IRS procedures.  We reviewed internal audit reports
and interviewed IRS internal auditors and inspectors at the
Philadelphia and Ogden service centers to supplement our
understanding and to obtain additional information and insight.  We
interviewed the Regional Inspector for the Northeast Region to obtain
details on incidents of thefts at IRS service centers.  We also
reviewed IRS' Summary Action Plan:  Protection of Monetary
Instruments, dated May 20, 1998, to consider IRS' proposed actions on
previously identified control weaknesses over monetary instruments,
as well as IRS' action plan dated June 4, 1998, to address control
deficiencies over recruitment, background, and security
investigations.  We have not performed subsequent site visits to
verify completed corrective actions reported by IRS.  However, we
intend to follow up on the status of these corrective actions as part
of our fiscal year 1998 financial statement audit. 

We performed our work from April 1998 through August 1998 in
accordance with generally accepted government auditing standards.  We
requested written comments on a draft of this report from the
Commissioner of Internal Revenue or his designee.  The Commissioner
provided us with written comments, which are discussed in the "Agency
Comments and Our Evaluation" section and are reprinted in appendix I. 


   DELAYS IN OBTAINING BACKGROUND
   INFORMATION COMPROMISE THE
   SECURITY OF TAXPAYER DATA AND
   RECEIPTS AT SERVICE CENTERS
------------------------------------------------------------ Letter :4

Despite the sensitivity of taxpayer data, we recognize that fully
limiting access to such data is not feasible given the nature of IRS'
operations.  Because the primary nature of IRS operations is to
process tax returns, most of the units within the service center work
with tax returns or other forms of tax data.  Therefore, sensitive
taxpayer information is accessible all over the service center.  As a
result, the vulnerability of this data to theft or misuse is
heightened.  This vulnerability thus underscores the need for
effective deterrent controls to aid in reducing the exposure of tax
data to such theft or misuse. 

To reduce the inherent risk in this exposure, IRS' policy is to
screen out job applicants that may pose a potential threat to IRS
operations.  IRS requires a fingerprint check on all permanent,
seasonal, and temporary employees hired to identify any prior arrests
and convictions.  In addition, IRS requires a background
investigation on all employees with a 90-day appointment or longer. 
However, IRS internal auditors reported that, in at least some
instances, and for numerous reasons which we discuss later in this
report, the results of these checks were not completed before the
individuals were placed in positions responsible for handling cash
receipts and taxpayer data.\6

The Comptroller General's Standards for Internal Controls in the
Federal Government\7 calls for employees to have personal and
professional integrity and to maintain a level of competence that
allows them to accomplish their assigned duties.  Because IRS
employees are entrusted with handling sensitive taxpayer information
of a financial and personal nature, as well as billions of dollars in
receipts, ensuring worker integrity through a carefully managed
recruiting and hiring process is an area demanding special attention
from IRS management. 

One way to assist in determining worker integrity is to ensure that
background investigations of an appropriate level are performed on
IRS employees.  A background investigation may involve contacting
prior employers, schools, and law enforcement agencies to inquire
about the applicant's qualifications, character, and other pertinent
factors.  The extent of the investigation depends on the employing
agency's risk assessment of the sensitivity of the position to be
occupied based on guidelines defined by the Office of Personnel
Management (OPM).  Currently, IRS classifies some Receipt and Control
Branch employees as occupying "low risk" positions.  These "low risk"
employees handle thousands of taxpayer receipts and sensitive
taxpayer information which require a high degree of public confidence
and trust.  Because "low risk" positions require the least
comprehensive type of investigation, background investigations for
such employees may fail to uncover all pertinent information
regarding the suitability of an individual to process taxpayer data
and receipts. 

However, background investigations are lengthy.  According to OPM,
even limited investigations take an average of 75 calendar days to
complete.  Because of the length of time it takes, IRS only requires
a background investigation for employees hired for periods of 90 days
or more.  To help screen individuals, such as seasonal and temporary
employees who are hired for less than 90 days, and to more quickly
identify potential problems with long-term employees before their
background investigations are completed, IRS initiates fingerprint
checks of all newly hired staff prior to employment.  IRS submits
candidates' fingerprints and preliminary background information on
each individual to OPM.  OPM then inputs the demographic information
into its database and transmits the information with the fingerprints
to the Federal Bureau of Investigations (FBI) to check against
national records.  According to IRS, OPM indicated that results of
fingerprint checks can be provided within 21 workdays.  However,
extensive delays in receiving fingerprint check results prevented IRS
from obtaining such pertinent information promptly.  The IRS internal
audit review mentioned previously reported that the turnaround time
for fingerprint checks averaged 68 days, with some fingerprint checks
taking as long as 141 days, instead of the 21 days indicated by OPM. 

The internal audit review also found that some service centers did
not take fingerprints of applicants or did not submit fingerprints in
a timely manner.  Furthermore, the review found that one service
center did not prescreen any 30-day temporary employees, while
another service center did not follow procedures requiring that
service centers prescreen employees prior to sending background
investigation packages for processing.  The review also found that
IRS personnel offices were reluctant to use the fingerprint
prescreening process because the results were not received before
employees reported to work. 

In February 1998, IRS convened a task team to study the service
center prescreening process.  The task team found that the delays
with fingerprint checks are due to a number of causes that are
partially attributable to IRS and partly to the FBI.  According to
the task team, not all service centers were fingerprinting applicants
at the earliest possible point.  Additionally, in some instances,
fingerprints had to be retaken because of their poor quality and thus
could not be processed by the FBI.  The task team also found that the
FBI's manual processing of fingerprints is labor intensive,
particularly for those prints that result in a possible match to the
FBI's database of arrest records.  The task team found that the FBI
had a backlog of 600,000 cases to process as of the date of their
study and that the FBI places a higher priority on processing law
enforcement requests for fingerprint checks than on requests related
to personnel investigations. 

The delays in fingerprint checks are particularly serious when they
are applied to seasonal and temporary employees.  According to IRS
data, a total of more than 20,000 seasonal employees were employed in
1998, of which more than 5,000 were new seasonal employees.  These
seasonal and temporary employees work an average of 8 to 10 weeks
during the peak filing season, and may have already finished their
term of employment before IRS receives the results of these
fingerprint checks.  In fact, the internal audit review discussed
above found that in four service centers where information was
available, as many as 5 percent of the 3,059 temporary and seasonal
employees hired and placed in the Receipt and Control Branch during
fiscal years 1996 and 1997 had backgrounds that contained arrests or
convictions.  If the results of fingerprint checks are not received
promptly by IRS, these individuals can be placed in positions to
steal receipts and taxpayer data. 

The failure to ensure that background investigations and fingerprint
checks are completed before employment in sensitive areas increases
the vulnerability of billions of dollars of cash and checks, as well
as taxpayer data, to theft and fraud.  According to the internal
audit review, of the 80 thefts of receipts at service centers
reported between January 1995 and July 1997, 12 were committed by
employees with previous arrest records for theft, assault, or drug
charges that were not identified prior to employment.  The
fingerprint prescreening results were not received before six of
these employees reported for work and fingerprint prescreenings were
not performed for the other six employees. 

To help address the slow turnaround time in receiving the results of
fingerprint checks, the Philadelphia Service Center (PSC) has
negotiated with local law enforcement to provide police checks on
prospective IRS employees.  Due to technical problems, PSC missed its
August 1998 target date to establish a working, on-line connection
between its fingerprinting machine and the local law enforcement's
fingerprint database.  However, once these problems are resolved, the
connection should enable PSC to transmit electronic fingerprint
images so that the local law enforcement's database can be checked
and PSC alerted of arrest records on IRS applicants within 24 hours. 
While this should result in a marked improvement, the database can
only identify crimes committed locally. 

On a nationwide basis, IRS has begun to address the fingerprint check
problem.  In response to a long-term solution recommended by the IRS
task team, IRS is in the process of procuring equipment that will be
compatible with the FBI's Integrated Automated Fingerprint
Identification System.  This system will allow for an automated
fingerprint classification.  According to IRS, the electronic
fingerprints, demographic information, and results from the FBI's
search will be channeled through OPM so that OPM can upload the
information into its database.  The FBI's goal with this system is to
process civil fingerprint checks within 24 hours.  IRS expects to
receive the results of the fingerprint check within 5 days.  IRS'
target date for implementation of this system is August 1999. 

In the meantime, IRS is exploring short-term solutions recommended by
the IRS task team to address problems with delayed fingerprint
results.  According to IRS' action plan, it has retrained employees
to take better quality fingerprints.  Other planned short-term
actions include 1) developing a policy to take fingerprints of filing
season applicants upon their first contact with IRS, 2) issuing
guidelines for service centers to contact local police agencies to
determine if they will provide police checks on prospective
employees, 3) determining the feasibility of moving employees from
other units so that only employees with completed fingerprint checks
are assigned to process receipts, and 4) bringing all service center
personnel offices on-line with OPM so that the offices can receive
background checks from OPM as soon as the results from FBI are
uploaded to OPM's database.  These additional actions, however, have
not yet been implemented. 


--------------------
\6 See Review of Remittance Processing Activities (Internal Revenue
Service, Office of the Chief Inspector, Reference No.  082503, March
24, 1998).  The Office of the Chief Inspector includes Internal
Audit, Internal Security, and Regional Inspections. 

\7 The Comptroller General's Standards for Internal Controls in the
Federal Government, issued in 1983, contains the internal control
standards to be followed by executive agencies in establishing and
maintaining systems of internal control as required by the Federal
Managers' Financial Integrity Act of 1982, as amended. 


      RECOMMENDATIONS
---------------------------------------------------------- Letter :4.1

To ensure that employees assigned to process receipts and sensitive
taxpayer data are subjected to the appropriate level of background
check, we recommend that the Commissioner reevaluate the risk
classification of all positions in IRS' Receipt and Control Branch
and reclassify such positions where appropriate. 

To reduce the incidence of applicants not subjected to fingerprint
checks, we recommend that the Commissioner (1) establish procedures
to review the applications and associated documents for all
applicants given job offers to ensure that fingerprint checks are
initiated on these individuals and (2) implement procedures to
provide supervisory feedback on these reviews as necessary to ensure
that personnel staff are aware of and follow IRS' policy requiring
fingerprint checks. 

To assist in the prompt receipt of fingerprint results of applicants,
we recommend that the Commissioner continue with the agency's plans
to develop and implement a policy to fingerprint filing season
applicants at the earliest possible time in the job application
process. 

We also recommend that until the problems with delays in fingerprint
checks are resolved, the Commissioner develop and implement a policy
prohibiting new employees from being assigned to process receipts
until results of fingerprint checks are received and reviewed by
management. 

To obtain background information on a more timely basis, we recommend
that the Commissioner continue the agency's efforts to explore the
feasibility of obtaining local police checks on IRS applicants and
evaluate the efficiency and effectiveness of PSC's electronic
fingerprinting system in order to supplement FBI fingerprint checks. 

In the long term, to decrease the turnaround time for FBI fingerprint
check results, we recommend that the Commissioner continue the
agency's efforts to negotiate with OPM and the FBI and procure the
necessary equipment so that it can participate in the FBI's
Integrated Automated Fingerprint Identification System program by
August 1999. 


   PHYSICAL SAFEGUARDS ARE
   INADEQUATE TO PROTECT CASH
   RECEIPTS
------------------------------------------------------------ Letter :5

The Comptroller General's Standards for Internal Controls in the
Federal Government requires that access to resources and records,
such as IRS receipts and taxpayer data, be limited to authorized
individuals in order to reduce the risk of unauthorized use or loss
to the government.  However, at the service centers and district
offices we visited, we identified internal control weaknesses that
allowed unauthorized access to such resources and records. 
Specifically, we found that IRS service centers did not (1) have
adequate controls to limit unauthorized access to receipts and
accompanying tax returns and (2) implement adequate safeguards over
returned refund and unmatched checks.  At district offices, we found
that IRS did not (1) adequately secure receipts as required by the
Internal Revenue Manual (IRM)\8 and (2) perform necessary
reconciliations to ensure accountability for district office
receipts.  Because IRS service centers and district offices directly
collected over $100 billion in fiscal year 1997 and are responsible
for processing all taxpayer data submitted by taxpayers, such
weaknesses increase the vulnerability of receipts and taxpayer data
to theft or misuse. 


--------------------
\8 The IRM prescribes the procedures that IRS employees must follow
when processing IRS documents and data. 


      SERVICE CENTERS LACKED
      ADEQUATE DETERRENT CONTROLS
      TO LIMIT UNAUTHORIZED ACCESS
      TO RECEIPTS
---------------------------------------------------------- Letter :5.1

During the peak filing season, the processing of receipts and returns
occurs 24 hours a day.  IRS handles and processes taxpayer receipts
and returns in several stages.  The Receipt and Control Branch at
each IRS service center is responsible for the receipt and initial
processing of mail containing receipts and returns delivered to the
service centers.  The branch is to be located in a restricted access
area limited to authorized personnel.  Staff extract the contents of
envelopes mailed by taxpayers, post the payment data to credit
taxpayers' accounts for the amounts received, and then endorse and
prepare the checks for deposit.\9 After the payments are processed,
units outside the Receipt and Control Branch review the tax returns
and post the tax return data to taxpayers' accounts.  The units that
post the tax return data are not located in restricted areas and are
thus accessible to all employees and nonemployees who have access to
an IRS service center. 

IRM 1(16)41 Physical Security Handbook, section 257.4, requires that
the mail extraction operation--the first stage of processing--take
place in a secured and restricted access area.  However, at the four
service centers we visited, mail that contained tax returns and
receipts was left in carts in open, unrestricted corridors or rooms. 
Because of limited space at the service centers, these areas served
as overflow storage when the units responsible for extracting mail
could not accommodate all the mail received during the peak filing
season.  At two of the service centers, both unopened mail and opened
mail that had been separated and clearly labeled as either "with
remittances" or "without remittances"\10 were stored in these areas. 
These overflow areas were not located in restricted access areas and,
thus, were easily accessible to anyone in the service center, such as
employees not authorized to process receipts or visitors who had no
need to access receipts or taxpayer data.  In fact, at one service
center, the corridor used as an overflow area was a heavily travelled
corridor used by employees carrying gym bags to access a fitness
center.  During our observations, no guards patrolled these areas in
three of the four service centers visited.  Although one service
center used surveillance cameras to monitor activities in the
corridor, the cameras' views of activities were obstructed by
7-foot-high carts used to store unsorted and sorted mail. 

At the end of the extraction process, IRS staff illuminate, or
"candle," all envelopes which have already gone through the
extraction process to ensure that all contents are actually removed
prior to the envelopes' destruction.  The final candling activity at
one service center was located in an unsecured room off an
unrestricted corridor.  Since the final candling activity is an
extension of the extraction of receipts and taxpayer data, this
operation should be located in a secured and restricted access area,
as required by IRM 1(16)41 Physical Security Handbook section 257.4. 
Because many checks are found during the candling process, the lack
of security over the candling area increases IRS' vulnerability to
theft or loss of checks. 

We also found that receipts discovered outside the Receipt and
Control Branch were not adequately accounted for and secured.  IRM
38(43)3.2, section (10), Service Center Deposit Activity, requires
that "discovered remittances" not delivered immediately to the units
responsible for depositing these receipts are to be held in locked
containers.  "Discovered remittances" are cash and/or checks that
were either erroneously overlooked during the extraction process or
that bypassed extraction because the receipts were sent unopened to
other units, such as the Offer-in-Compromise Unit.  The IRM further
requires that as each such receipt is discovered, it is to be
recorded by a supervisor on a control log.  At two service centers,
we observed numerous checks left on desks, shelves, or file folders
in unsecured areas, such as the Code and Edit Unit and the
Offer-in-Compromise Unit. 

At one of the service centers where we performed additional work, we
found that these checks were not recorded on control logs until they
were ready to be taken for receipt processing and deposit.  We were
informed that during the peak filing season, these checks were
recorded on control logs and submitted to the appropriate unit for
receipt processing on an hourly basis.  However, prior to doing so,
unsecured and unattended checks outside restricted areas were
susceptible to theft by any individual who had access to the service
center. 

Prior IRS internal audits and other internal reviews have identified
other weaknesses in controls over the safeguarding of receipts.  In
response to these findings, each service center provided IRS
management with its respective corrective action plan, which was then
incorporated into IRS' Summary Action Plan:  Protection of Monetary
Instruments, dated May 20, 1998.  The plan reported corrective
actions pending and some completed for weaknesses noted at specific
service centers.  However, the plan did not specifically address the
use of overflow areas for storing receipts, nor did it address the
weaknesses over "discovered remittances".  Additionally, the plan
addressed the candling issue only at sites other than the one where
we noted the weakness. 


--------------------
\9 The unit responsible for posting payments to taxpayer accounts is
sometimes organizationally part of the Receipt and Control Branch and
sometimes part of the Data Conversion Branch, depending on the
service center.  However, at the service centers we visited, this
unit was always physically located in the Receipt and Control
Branch's restricted access area. 

\10 IRS uses the terms "remittances" and "receipts" interchangeably
to refer to taxpayers' payments against their tax liabilities.  To
the taxpayer, such amounts are remittances (payments), but to IRS
they are receipts. 


      SERVICE CENTERS LACKED
      ADDITIONAL SAFEGUARDS OVER
      UNMATCHED AND RETURNED
      REFUND CHECKS
---------------------------------------------------------- Letter :5.2

Certain receipts that are particularly vulnerable to theft, such as
"unmatched" and returned refund checks, were not properly secured. 
Unmatched checks are those checks that were inadvertently separated
from their accompanying vouchers or tax returns or were mailed to the
service center without any instructions from the taxpayers as to how
the payments should be applied.  Without such instructions, such
checks must be set aside until they can be researched to determine
which taxpayers' accounts should be credited.  At all service
centers, unmatched checks are not subject to additional security but
are stored in open baskets accessible to all who have access to the
Receipt and Control Branch.  As a result, these unmatched checks are
particularly vulnerable to theft because they are not immediately
processed and are stored in open baskets for long periods of time. 

Returned refund checks are Treasury refund checks that are sent to
taxpayers and subsequently returned uncashed to IRS as payment
against other tax liabilities.  IRM 3.8.43, Service Center Direct
Receipts - Service Center Deposit Activity, section 43.4.2.47,
requires refund checks returned to IRS by taxpayers to be stamped
"non-negotiable." Although the IRM does not state when the returned
refund checks should be voided, some of these checks were already
endorsed by the taxpayers, making them highly negotiable. 
Consequently, they should be voided as soon as they are extracted. 
However, at two service centers, returned refund checks discovered by
the Extraction Unit were handled by several employees before they
were voided.  These returned refund checks were left in unsecured
bins or file folders on desks prior to being stamped
"non-negotiable," significantly increasing the risk of theft. 
According to internal auditors at one service center, seven returned
refund checks totalling $300,000 were stolen from that service
center.  This demonstrates the susceptibility of these refund checks
to theft. 

IRS internal audit similarly identified weaknesses over the handling
of returned refund checks and recommended establishing tighter
controls over these instruments.  According to IRS' Summary Action
Plan:  Protection of Monetary Instruments, IRS is pursuing a plan of
action to address this weakness.  However, no changes have yet been
implemented. 


      DISTRICT OFFICES DID NOT
      ADEQUATELY SECURE RECEIPTS
---------------------------------------------------------- Letter :5.3

Although district offices do not receive the same volume of receipts
as service centers, it is nonetheless important for such offices to
diligently control access to and accountability for their receipts. 
However, as in the service centers, we found weaknesses in the
internal controls over district office receipts that expose them to
risk of theft or loss. 

Procedures for handling receipts at district offices vary slightly
depending on whether the district office has a teller function.  In
all cases, however, the Customer Service Unit at the district office
collects walk-in payments and tax returns from the taxpayers.  If the
district office has a teller function, walk-in payments are submitted
to the Teller Unit, which posts receipt data into the IRS database in
the same way the service centers do.\11 These district offices use
couriers to deliver their checks for deposit to the bank and to
deliver any accompanying tax returns to the service centers for
processing.  If the district office does not have a teller function,
the Customer Service Unit collects walk-in payments and returns and
transmits all the documents via courier to the service center for
processing. 

IRM 1(16)(41), Physical Security Handbook, section 500, "Minimum
Protection Standards," establishes a nationwide, uniform method of
protecting items which require safeguarding.  Specifically, it
requires that checks and currency be stored in locked containers and
that the keys to access those containers also be stored in a locked
container.  At the three district offices visited, we observed
receipts stored in unlocked containers during the day and, at two
district offices, in containers accessible to numerous employees
overnight.  Specifically, we found the following: 

  -- At one district office, Customer Service employees left their
     desks unattended during the day, even though receipts were
     stored in drawers and the keys were still in the locks.  At the
     end of the day, employees emptied their desk drawers of receipts
     in order to store them in a file cabinet overnight.  If an
     employee left early, another employee would empty the drawer of
     receipts for overnight storage.  The key to the file cabinet was
     accessible to all employees assigned to that unit. 

  -- At another district office, Customer Service employees stored
     receipts in an unlocked cash box.  The Customer Service area was
     accessible to all IRS employees at the district office.  The
     receipts were locked in a file cabinet at the Teller Unit area
     overnight, and the key to the cabinet was stored in an unlocked
     desk.  Several employees in the unit were aware of where the key
     was stored. 

  -- In the third district office, receipts were stored in an open
     bin during the day.  These receipts were stored overnight in a
     locked cabinet.  At this district office, access to the cabinet
     was limited to two people in the unit. 

The use of unsecured containers to store receipts, or the failure to
limit storage container accessibility to employees designated to open
such containers, increases the potential for theft. 


--------------------
\11 Due to the presence of different systems, the service centers and
the district offices might initially post receipts on different
systems.  However, after processing, data from the different systems
eventually feed into the main IRS database, which contains data on
both payments received and taxes owed. 


      DISTRICT OFFICES DID NOT
      PERFORM NECESSARY
      RECONCILIATION TO ENSURE
      ACCOUNTABILITY
---------------------------------------------------------- Letter :5.4

To ensure proper access to and accountability for resources, the
Comptroller General's Standards for Internal Controls in the Federal
Government specifies that periodic comparisons should be made between
resources and records and that the frequency of such comparisons be
determined by the vulnerability of the asset.  However, at all three
district offices we visited, receipts were not recorded in control
logs or transmittal sheets until a few hours after receipt or even
the following day.  Additionally, no one reconciled the receipts
against the control logs prior to or after overnight storage and
prior to submitting them to the district office teller unit or to the
service centers for processing.  Given the weaknesses in securing
receipts discussed above, the failure to immediately record receipts
in control logs and to reconcile these control logs to receipts on
hand decreases the likelihood of the timely detection of theft of
receipts.  Under current practices, incidents of theft may not come
to IRS' attention until taxpayers receive erroneous default notices
or identify anomalies in their cancelled checks or bank statements
and contact IRS. 


      RECOMMENDATIONS
---------------------------------------------------------- Letter :5.5

To ensure that the mail extraction process takes place in a secure
and restricted access area, as required by the IRM, we recommend that
the Commissioner improve the physical security controls over receipts
and returns stored in unsecured overflow areas.  These controls might
include limiting unnecessary traffic by temporarily designating these
overflow areas as restricted access areas and/or posting additional
security guards over such areas during the peak filing season. 

To limit exposure to theft and provide adequate monitoring in
accordance with IRM requirements, we recommend that the Commissioner
ensure that all final candling activities are consistently located in
a restricted access area. 

To reduce the vulnerability of receipts found outside restricted
access areas, we recommend that the Commissioner provide secure
containers for service center employees to store "discovered
remittances" prior to inventory and submission to the Receipt and
Control Branch.  Immediately upon discovery, the receipts should be
recorded into a control log, the receipts secured in a locked
container, and the discovered receipts reconciled to the control log
prior to submission for processing. 

To reduce the vulnerability of receipts that are especially
susceptible to theft and misuse, we recommend that the Commissioner
ensure that all unmatched checks are stored in locked containers
until they can be researched and processed for deposit. 

To reduce the vulnerability of returned refund checks to theft, we
recommend that the Commissioner ensure that all returned refund
checks are stamped "non-negotiable" as soon as they are extracted. 

To better safeguard receipts at district offices, we recommend that
the Commissioner require district office employees to store walk-in
payments in secure containers in accordance with IRM 1(16)(41),
section 500.  District office management should ensure that this
policy is followed and should limit the number of employees with
access to the keys or combination to these containers. 

To improve accountability for walk-in payments received, we recommend
that the Commissioner ensure that these receipts are recorded in a
control log prior to depositing the receipts in the locked container
and ensure that the control log information is reconciled to receipts
prior to the submission of the receipts to another unit for payment
processing.  To ensure proper segregation of duties, the
reconciliation should be performed by an employee not responsible for
logging receipts in the control log. 


   COURIER SECURITY DOES NOT
   ADEQUATELY PROTECT DEPOSITS AND
   SENSITIVE TAXPAYER DATA FROM
   THEFT OR LOSS
------------------------------------------------------------ Letter :6

Proper safeguarding of assets requires that IRS ensure adequate
security over receipts from the time they are received at the service
center until the time they are deposited at financial depository
institutions.  However, at all four service centers we visited,
receipts for deposits were picked up from the service centers by a
single unarmed, plain-clothes courier for delivery to the depositing
bank.  During our visits, these couriers were entrusted with
transporting peak season deposits ranging from $100 million to almost
$200 million for each deposit twice a day.  At one district office,
we observed that the courier was a bicycle messenger entrusted with
over $1 million of receipts during nonpeak season to more than $100
million per deposit during the peak season. 

Deposits were also improperly safeguarded during pickup.  At one
service center, we observed that the courier left deposits unattended
in the car while he returned inside the service center to pick up
another batch of deposits.  At another service center, we observed
that the courier left deposits worth over $200 million unattended in
the vehicle with the window open while he returned a borrowed cart to
the interior of the service center.  Onlookers at this service center
were aware of the nature of the courier's visit. 

According to a commercial bank and courier company officials, banking
industry practice is generally to use unarmed couriers to transport
checks and armored vehicles to transport currency.  Therefore, IRS'
current practice of transporting checks via unarmed couriers is
similar to current banking industry practices.\12 However, because of
the magnitude of IRS' deposits, both in dollars and the number of
checks, and the sensitivity of taxpayer information contained on the
checks,\13 the security provided by the unarmed courier services may
be inadequate to meet IRS' responsibility to protect government
assets and personal taxpayer information. 

During the peak filing season, one service center deposit typically
has tens of thousands of checks.  If a deposit were lost or stolen,
IRS would have to expend substantial efforts to initiate actions to
recover stolen checks and prevent them from being negotiated. 
However, even if stolen checks are not cashed, they can be used for
check cloning schemes, and sensitive personal information on these
checks can be used to perpetrate identity fraud.  Such an incident of
loss or theft could result in the loss of funds and financial damage
and could impose considerable burden on the taxpayers.  Any such
incident would greatly reduce the taxpayer's confidence in IRS'
ability to safeguard tax receipts and the taxpayer's personal data. 

Due to differences in courier contracts, IRS is not consistently
covered in the event of deposits being lost, stolen, or damaged in
transit.  In some contracts, the bank provides the courier service
and the liability insurance for deposits in transit.  In these
instances, the bank is liable for the loss, theft, or destruction of
any deposit from the time it is picked up from IRS by the bank's
courier.  If the deposits are stolen, the bank is liable for any loss
that IRS cannot recover after IRS has notified the taxpayers, issued
stop payment orders, and received replacement checks.  However, in
other cases where IRS directly contracts with the courier service,
the courier service is only liable up to the limit specified in the
contract.  This limit varies between $350,000 in a contractual
agreement for one service center to $1 million for another service
center, while other contracts did not specifically refer to liability
coverage.  Because of the high dollar value and the volume of checks
involved in one peak season shipment of deposits, the government
could be exposed to losses which exceed the courier's contractual
liability if all the lost or stolen checks cannot be recovered. 

We also observed inconsistencies in the physical access rights to
service centers that IRS provided to the couriers.  At three of the
service centers, IRS employees delivered the daily deposits from the
Receipt and Control Branch to the couriers in the lobby or outside
the building.  However, at one service center, the courier was
provided a restricted access area badge after checking in with the
guard.  This type of badge provided the courier greater access within
the service center than most service center employees because it
entitled the courier access to both unrestricted and restricted areas
within the service center.  This courier then proceeded to walk
unescorted through the service center where tax returns were
processed and entered the payment processing area through one of the
restricted access doors not guarded by a door monitor.  Because tax
returns were stored unsecured and sometimes unattended throughout the
service center and unprocessed receipts were stored in open baskets
throughout the payment processing area, taxpayer data and checks were
accessible to an individual who did not have a need to access them. 


--------------------
\12 At the sites we visited, IRS converted any currency received into
cashiers' checks, usually at a credit union located on IRS premises. 
Therefore, at these sites, deposits transported by the couriers
consisted only of checks. 

\13 Most checks received by service centers are processed through the
Remittance Processing System, which automatically encodes the back of
each check with the taxpayer's social security number. 


      RECOMMENDATIONS
---------------------------------------------------------- Letter :6.1

To ensure that IRS meets its responsibility to protect government
assets and taxpayer information, we recommend that the Commissioner
study the feasibility of improving security for its deposits in
transit.  In conducting this study, IRS should consider a number of
alternatives, including the use of depositories in closer proximity
to its various field locations and employing security guards to
accompany couriers to the depositories. 

To limit exposure to losses of deposits in transit, we recommend that
the Commissioner develop a policy to ensure that contracts related to
courier services do not unduly expose the government to losses in the
event of lost, stolen, or damaged deposits in transit. 

To limit courier access to sensitive taxpayer information and
unguarded receipts in the Receipt and Control Branch, we recommend
that the Commissioner ensure that courier access is limited to
service center premises.  Deposit unit employees should deliver the
deposits to couriers waiting at the guard station instead of
providing couriers badges allowing them unnecessary service center
access. 


   AGENCY COMMENTS AND OUR
   EVALUATION
------------------------------------------------------------ Letter :7

In commenting on this report, the Commissioner of Internal Revenue
generally agreed with our findings and recommendations and noted that
IRS has or would be taking action to address the issues raised in the
report.  These actions include

  -- conducting an analysis of risk classifications of positions in
     the Receipt and Control Branch to ensure background checks are
     commensurate with the level of risk associated with the
     position;

  -- ensuring IRS has the necessary equipment to participate in the
     FBI's Integrated Automated Fingerprint Identification System
     program by August 1999;

  -- working with each service center to determine appropriate
     methods for securing overflow areas and ensuring all final
     candling areas are located in restricted access areas;

  -- exploring various options for security containers for unmatched
     checks and implementing a process for such storage by August
     1999;

  -- revising procedures to require stamping all returned refund
     checks "non-negotiable" as soon as they are extracted from
     envelopes;

  -- revising procedures for safeguarding receipts received in
     walk-in facilities and for maintaining a control log of receipts
     received and deposited or transferred to another unit by January
     1999; and

  -- studying alternative methods for transporting deposits to
     depositories and service center practices for limiting courier
     access to service centers. 

These actions are generally consistent with the recommendations
contained in our report and, if effectively implemented, would assist
IRS in reducing the risk of loss or misuse of receipts and taxpayer
information.  However, there are a number of our recommendations for
which IRS' responses do not appear to adequately address. 
Specifically, IRS stated it would work with the Office of Personnel
Management and IRS' General Legal Services to determine when job
applicants can be fingeprinted and would, to the extent possible,
prohibit new employees from processing receipts until the results of
fingerprint checks are received and reviewed by management.  However,
IRS noted that to wait for the results of fingerprint checks before
hiring seasonal employees in the service centers would adversely
affect IRS' ability to collect and process tax returns.  IRS also
stated that it would not always be possible to prohibit new employees
from processing receipts during its April peak returns processing
period.  However, it is particularly during these peak periods when
receipts and taxpayer information are most susceptible to theft. 
Consequently, we believe that to further reduce such risk, IRS should
carefully consider the need to have fingerprint checks performed
prior to hiring new employees and have the results of all fingerprint
checks reviewed prior to allowing personnel to handle taxpayer
receipts and data. 

With regard to our recommendation that IRS provide secure containers
for service center employees to store discovered remittances prior to
inventory and submission to the Receipt and Control Branch and to
maintain an inventory of these remittances on a control log, IRS
noted that it currently has procedures which require service centers
to store such remittances in a secure container and to record
remittance information.  However, we found that these procedures were
not uniformly followed by the service centers.  Consequently, IRS
will need to be proactive in providing secure containers to the
service centers and in ensuring records are maintained of discovered
remittances. 


---------------------------------------------------------- Letter :7.1

This report contains recommendations to you.  The head of a federal
agency is required by 31 U.S.C.  720 to submit a written statement on
actions taken on these recommendations.  You should send your
statements to the Senate Committee on Governmental Affairs and the
House Committee on Governmental Reform and Oversight within 60 days
after the date of this letter.  A written statement also must be sent
to the House and Senate Committees on Appropriations with the
agency's first request for appropriations made over 60 days after the
date of this letter. 

We are sending copies of this report to the Secretary of the Treasury
and the Director of the Office of Management and Budget.  We are also
sending it to the Chairmen and Ranking Minority Members of the Senate
Committee on Appropriations and its Subcommittee on Treasury and
General Government; Senate Committee on Finance and its Subcommittee
on Taxation and IRS Oversight; Senate Committee on Governmental
Affairs; Senate Committee on the Budget; House Committee on
Appropriations and its Subcommittee on Treasury, Postal Service, and
General Government; House Committee on Ways and Means; House
Committee on Government Reform and Oversight and its Subcommittee on
Government Management, Information and Technology; House Committee on
the Budget; and other interested congressional committees.  Copies
will be made available to others upon request. 

Please contact me at (202) 512-9505 or Steven J.  Sebastian,
Assistant Director, at (202) 512-9521 if you or your staff have any
questions concerning this report.  Major contributors to this report
are listed in appendix II. 

Sincerely yours,

Gregory D.  Kutz
Associate Director, Governmentwide Accounting
and Financial Management Issues




(See figure in printed edition.)Appendix I
COMMENTS FROM THE INTERNAL REVENUE
SERVICE
============================================================== Letter 



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)


The following is GAO's comment on the Internal Revenue Service's
letter dated October 29, 1998. 


   GAO COMMENT
------------------------------------------------------------ Letter :8

1.  Discussed in the "Agency Comments and Our Evaluation" section. 


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix II

ACCOUNTING AND INFORMATION
MANAGEMENT DIVISION, WASHINGTON,
D.C. 

Steven Sebastian, Assistant Director
Charles Fox, Assignment Manager
Paul Foderaro, Assignment Manager

ATLANTA FIELD OFFICE

Aditi Archer, Senior Auditor
Alva Archie, Auditor
Veronica Mayhand, Auditor
Angel Sharma, Auditor

DALLAS FIELD OFFICE

George Jones, Senior Auditor
Ellen Wolfe, Senior Auditor
Michael Coy, Senior Auditor
Leonard Zapata, Senior Auditor

SAN FRANCISCO FIELD OFFICE

Ellen Rominger, Senior Auditor
Laurie King, Auditor

LOS ANGELES FIELD OFFICE

Barbara House, Senior Auditor
Stacey Osborn, Auditor

SEATTLE FIELD OFFICE

Doreen Eng, Assistant Director
Delores Lee, Auditor-In-Charge
Tuyet-Quan Thai, Auditor-In-Charge
Pat Seaton, Senior Auditor


*** End of document. ***