Internal Revenue Service: Custodial Financial Management Weaknesses
(Letter Report, 08/04/1999, GAO/AIMD-99-193).

The Internal Revenue Service (IRS) continues to be plagued by serious
internal control weaknesses that have led to disbursements of fraudulent
and other questionable tax refunds, IRS employees stealing taxpayer
receipts, and errors or delays in posting payments to taxpayers'
accounts. These control weaknesses fall into five major categories: (1)
unpaid assessments, (2) security over receipts and taxpayer information,
(3) refunds and earned income tax credits, (4) revenue reporting and
distribution, and (5) financial reporting. Some weaknesses were evident
in GAO's first audit of IRS' financial statements in fiscal year 1992.
Some weaknesses are more pervasive than GAO had previously reported. For
example, GAO found varying degrees of weaknesses over the security of
receipts and taxpayer information at all 10 IRS service centers, at
other IRS offices, and at banks that process taxpayer information for
IRS. Until IRS corrects these shortcomings--such as ensuring that
taxpayer accounts are properly credited for payments made--these
conditions will undermine IRS' ability to deliver quality customer
service.

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

 REPORTNUM:  AIMD-99-193
     TITLE:  Internal Revenue Service: Custodial Financial Management
	     Weaknesses
      DATE:  08/04/1999
   SUBJECT:  Accounting procedures
	     Federal agency accounting systems
	     Financial records
	     Financial statement audits
	     Internal controls
	     Financial management
	     Tax administration systems
	     Tax refunds
	     Reporting requirements
	     Auditing procedures
IDENTIFIER:  Highway Trust Fund
	     Black Lung Disability Trust Fund
	     Airport and Airway Trust Fund
	     Earned Income Tax Credit
	     EIC

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    United States General Accounting Office GAO                Report
    to the Commissioner of Internal Revenue August 1999
    INTERNAL REVENUE SERVICE Custodial Financial Management Weaknesses
    GAO/AIMD-99-193 United States General Accounting Office
    Accounting Information and Washington, D.C. 20548
    Management Division B-282731
    Letter August 4, 1999 The Honorable Charles O. Rossotti
    Commissioner of Internal Revenue Dear Mr. Rossotti: Over the past
    6 years, we have issued numerous reports about the Internal
    Revenue Service's (IRS) internal controls over its financial
    operations. These operations dwarf most other financial activities
    undertaken by any single entity, public or private, in the world.
    While the enormity of the task heightens the need for effective
    financial management, our previous audit work identified serious
    financial management system deficiencies and internal control
    weaknesses that have resulted in losses to the federal government
    and unnecessary burden to taxpayers.  Many of these deficiencies
    continued to exist throughout fiscal year 1998.  In our report on
    the results of our audit of IRS' fiscal year 1998 financial
    statements and in related testimony before Congress, we reported
    that serious control weaknesses continue to exist,1 and that these
    weaknesses result in our continuing to identify IRS financial
    management as a high risk area.2 This report addresses internal
    control and compliance issues related to IRS' custodial
    activities, which include collecting federal tax revenues,
    refunding tax overpayments, and pursuing collection of amounts
    owed.  It is one of several reports relating to specific issues we
    identified in our fiscal year 1998 audit.3  With regard to these
    custodial activities, this report discusses (1) previously
    reported internal control and compliance issues 1Financial Audit:
    IRS' Fiscal Year 1998 Financial Statements (GAO/AIMD-99-75, March
    1, 1999) and Internal Revenue Service: Results of Fiscal Year 1998
    Financial Statement Audit (GAO/T-AIMD-99-103, March 1, 1999). 2See
    High Risk Series: An Update (GAO/HR-99-1, January 1999). 3We will
    also be issuing separate reports related to financial management
    of IRS' administrative operations and its computer security.
    Letter           Page 1                    GAO/AIMD-99-193  IRS
    Custodial Financial Management Weaknesses B-282731 and related
    recommendations,4 (2) new issues identified during our fiscal year
    1998 financial audit,5 along with new recommendations to address
    those issues, and (3) additional issues identified from our
    ongoing fiscal year 1999 financial audit. Results in Brief
    IRS continues to have a broad range of serious internal control
    weaknesses that have resulted in disbursements of fraudulent and
    other questionable tax refunds, unnecessary burden to taxpayers
    resulting from taxpayer receipts stolen by IRS employees, and
    errors or delays in posting payments to taxpayer accounts.  These
    control weaknesses fall into five major areas: (1) unpaid
    assessments, (2) security over receipts and taxpayer information,
    (3) refunds and earned income tax credits, (4) revenue reporting
    and distribution, and (5) financial reporting.  Some weaknesses
    are long-standing, having been reported since our first audit of
    IRS' financial statements in fiscal year 1992.6  In addition, we
    have found that some weaknesses are more pervasive than we
    previously reported.  For example, we have now found weaknesses
    over the security of receipts and taxpayer information in varying
    degrees at all 10 IRS service centers, at other IRS offices, and
    at banks that process taxpayer receipts for IRS.  Until IRS
    corrects these weaknesses-such as ensuring that taxpayer accounts
    are properly credited for payments made-these conditions will
    adversely impact IRS' ability to provide quality customer service.
    Weaknesses in the areas we identified include the following: *
    Unpaid tax assessments.  IRS does not have a detailed list, or
    subsidiary ledger, which tracks and accumulates unpaid assessments
    and their status on an ongoing basis.  As a result, IRS is unable
    to properly manage its unpaid assessments.  Deficiencies in IRS'
    systems that track 4See Financial Audit:  Examination of IRS'
    Fiscal Year 1997 Custodial Financial Statements (GAO/AIMD-98-77,
    February 26, 1998), Internal Revenue Service:  Immediate and Long-
    Term Actions Needed to Improve Financial Management (GAO/AIMD-99-
    16, October 30, 1998), Excise Taxes: Internal Control Weaknesses
    Affect Accuracy of Distributions to the Trust Funds (GAO/AIMD-99-
    17, November 9, 1998), and Internal Revenue Service:  Physical
    Security Over Taxpayer Receipts and Data Needs Improvement
    (GAO/AIMD-99-15, November 30, 1998). 5See Financial Audit:
    Examination of IRS' Fiscal Year 1998 Financial Statements
    (GAO/AIMD-99-75, March 1, 1999). 6See Financial Audit:
    Examination of IRS' Fiscal Year 1992 Financial Statements
    (GAO/AIMD-93-2, June 30, 1993) and Financial Management:
    Important IRS Revenue Information is Unavailable or Unreliable
    (GAO/AIMD-92-22, December 21, 1993). Letter    Page 2
    GAO/AIMD-99-193  IRS Custodial Financial Management Weaknesses B-
    282731 unpaid assessments have resulted in pursuit and collection
    of amounts from taxpayers that had already been paid. * Security
    over receipts and taxpayer information.  IRS' internal controls do
    not adequately safeguard assets such as cash, checks, and
    sensitive taxpayer information from loss or theft.  For example,
    in at least six of the service centers, delays in background
    investigations resulted in employees being hired and handling
    receipts and taxpayer information before the results of background
    checks were available.  According to IRS, at four of these service
    centers, background check results disclosed that 273 (5 percent)
    of approximately 5,400 employees hired to handle taxpayer data
    and/or receipts, had falsified key information on their
    applications.  Of the 273 employees, 64 (23 percent) had
    significant unsuitable backgrounds, such as criminal convictions,
    which resulted in their termination or forced resignation.  As
    late as March 1999, background investigations were still pending
    on some employees hired in fiscal year 1998 and still working for
    IRS-about 5 months after the end of the fiscal year. * Refunds and
    earned income tax credits.  IRS continues to lack adequate
    preventive controls to effectively reduce the risk of issuing
    inappropriate refunds.  For example, in our fiscal year 1998
    audit, we continued to find some refunds that should not have been
    issued.  These weaknesses in preventive controls over refunds are
    further exacerbated by high amounts of invalid earned income tax
    credit claims. * Revenue reporting and distribution.  IRS cannot
    routinely track and report amounts collected for Social Security,
    Hospital Insurance, individual income taxes, and excise tax-
    related trust funds.  Although IRS recently changed its method of
    distributing excise tax receipts to comply with the law, the new
    method is complex, cumbersome, and prone to significant error.
    For example, as a result of an IRS error in the certification
    process, all excise tax-related trust funds received understated
    amounts of distributions.  For the  Highway Trust Fund, this error
    was $92 million.  IRS corrected these errors once we brought them
    to its attention. * Financial reporting.  We continued to find
    that IRS' general ledger for custodial activities cannot routinely
    generate reliable and timely financial information for management
    decision-making.  IRS' financial systems do not conform to the
    U.S. Government Standard General Ledger and material balances are
    not supported by subsidiary ledgers. Due to these weaknesses, IRS
    systems do not comply with the Federal Financial Management
    Improvement Act (FFMIA) of 1996, which requires that financial
    management systems comply with federal accounting and systems
    standards. Page 3                  GAO/AIMD-99-193  IRS Custodial
    Financial Management Weaknesses B-282731 IRS has acknowledged the
    seriousness of its financial management problems and the
    Commissioner has committed to making necessary improvements.
    Although some needed improvements can be achieved in the short
    term, we recognize that for many weaknesses, systems modernization
    will need to be part of a long-term solution.  IRS has begun-and
    in some cases, completed-actions to address some of these
    problems.  For example, in the short term, IRS is developing and
    implementing various security procedures to better safeguard cash,
    checks, and taxpayer data.  These procedures include purchasing
    and installing equipment that, if properly linked with the FBI,
    will provide fingerprint check results before new employees report
    to duty.  However, we recognize that addressing other critical
    recommendations, such as the system deficiencies affecting IRS'
    ability to effectively manage and report on its unpaid
    assessments, will require system modifications that could take
    years to fully implement.  Such long-term efforts will require
    sustained senior management commitment in order for IRS to have
    sound financial management.  To help IRS accomplish these changes,
    we are making several recommendations on the newly reported
    issues. IRS acknowledged the magnitude of its system deficiencies
    and internal control weaknesses in comments on this report.  It
    noted that it was working on many of the matters that can be
    addressed in the short term, but recognized the long-term
    challenges posed by many of these issues and the need to factor
    them into its system modernization plans. Background    IRS is
    responsible for collecting federal tax revenues, refunding tax
    overpayments, and pursuing collection of amounts owed.  In fiscal
    year 1998, IRS collected nearly $1.8 trillion in tax revenues,
    issued $151 billion in tax refunds, and had net taxes receivable
    at fiscal year-end of $26 billion. Although most of the $1.8
    trillion in revenue was collected by intermediaries such as
    financial depository institutions and transferred directly to the
    Treasury general fund, IRS offices and lockbox banks7 collected
    $356 billion in fiscal year 1998.  These IRS offices include 10
    service centers nationwide that have collection, refund and
    enforcement responsibilities, as well as district and post-of-duty
    offices that IRS has 7A lockbox bank refers to a commercial bank
    with a designated post office box to which taxpayers are
    instructed to mail their payments and related tax documents.
    These lockbox banks process the documents, deposit the payments,
    then forward the documents and data to the service centers to
    update taxpayers' accounts. Page 4                   GAO/AIMD-99-
    193  IRS Custodial Financial Management Weaknesses B-282731
    established to assist taxpayers and perform collection and
    enforcement activities.  Ten commercial lockbox banks also receive
    and process taxpayer receipts, then forward the tax data to IRS
    for input and processing.8 Fiscal year 1997 marked the first time
    we were able to conclude that financial information, as presented
    in IRS' custodial financial statements, was reliable.  For fiscal
    year 1998 we again concluded that IRS' tax revenues, refunds, and
    net taxes receivable were reliable.9  However, in both years, we
    were able to reach this conclusion only after IRS applied
    extensive ad hoc programming and analysis to its financial
    information, resulting in material adjustments to derive reliable
    amounts and balances for its tax administration activities
    reported in the financial statements. These extensive procedures
    are needed to compensate for chronic system deficiencies that
    prevent IRS from having custodial information readily available
    for routine use, reporting, and decision-making. Objectives,
    Scope, and  The objectives of this report are to (1) discuss
    previously reported internal Methodology
    control and compliance issues and related recommendations, (2)
    present new issues identified during our fiscal year 1998
    financial audit, along with new recommendations to address those
    issues, and (3) present additional issues identified from our
    ongoing fiscal year 1999 financial audit. Appendix I provides
    further details on our scope and methodology. We conducted our
    work from April 1998 through April 1999 in accordance with
    generally accepted government auditing standards and Office of
    Management and Budget (OMB) Bulletin 98-08.  We requested comments
    on a draft of this report from the Commissioner of Internal
    Revenue or his designee.  The Commissioner's designee provided us
    with written comments, which are discussed in the "Agency Comments
    and Our Evaluation" section and reprinted in appendix III.
    8Treasury's Financial Management Service contracts with such banks
    on IRS' behalf. 9During fiscal year 1998, IRS combined the
    financial reporting of its administrative and custodial
    activities, which had previously been reported and audited
    separately, into a single set of principal financial statements.
    This required IRS to include both administrative and custodial
    activities on its balance sheet.  Our opinion on the statement of
    custodial activity was unqualified.  However, our opinion on the
    balance sheet was qualified due to administrative issues, not
    custodial issues.  These administrative issues will be covered in
    a separate report. Page 5                     GAO/AIMD-99-193  IRS
    Custodial Financial Management Weaknesses B-282731 Significant
    Weaknesses  IRS continues to lack controls to ensure effective
    management and Continue to Hinder
    accurate reporting of unpaid assessments.10  For example, IRS does
    not have a subsidiary ledger which tracks and accumulates unpaid
    assessments IRS' Ability to Manage  and their status on an ongoing
    basis, the absence of which adversely affects Unpaid Assessments
    its ability to effectively manage and accurately report these
    assessments. As a result, it cannot readily prevent or detect
    errors in the accounts of taxpayers that owe such assessments.  In
    some instances, this can result in taxpayers being pursued for
    amounts that have already been paid; in other instances, it can
    result in lost revenue to the government.   Table 1 summarizes the
    weaknesses we identified related to unpaid assessments, both in
    the past and in our most recent work along with their effect and
    IRS' actions to address these issues. Table 1:  Internal Control
    and Compliance Issues Related to Unpaid Assessments Internal
    control/compliance issues and effects
    IRS actions to address issues Issues previously reported Issue:
    IRS lacks a subsidiary ledger to track and accumulate
    IRS action:  IRS plans to implement a new subsidiary ledger unpaid
    assessments.  To compensate, it must use ad hoc programs  system
    as part of its systems modernization effort.  In the to classify
    the categories of its unpaid assessments for the annual  meantime,
    IRS must continue to use its ad hoc programs to prepare financial
    statements.
    its financial statements. Effect:  IRS cannot routinely
    distinguish categories of taxes due              GAO response:
    Weaknesses will continue to exist in this area until and their
    status.
    an effective subsidiary ledger is established. Issue:  Key IRS
    systems are not linked to ensure that all parties              IRS
    action: IRS issued directives to service center staff to reiterate
    liable for particular assessments receive proper credit for
    payments  that they must manually eliminate assessments that have
    already against those assessments.
    been paid from all taxpayer accounts. Effect:  GAO has found
    taxpayers were erroneously pursued for                  GAO
    response: Based on our fiscal year 1998 audit results, IRS'
    nonpayment or had liens placed on their property even though the
    efforts to manually fix these problems were ineffective.  Unless
    IRS liability had already been paid.
    is able to develop effective solutions, these problems will likely
    continue. Issue:  IRS had problems locating adequate supporting
    documents  IRS action:  IRS does not plan to implement our
    previous for individual unpaid balances.
    recommendation to establish checklists for collection documents
    until January 2001. Effect:  IRS may find it difficult to identify
    and focus collection            GAO response: While some
    improvements were noted, we found efforts on cases most likely to
    be collectible.  This condition also           IRS still had
    trouble providing support for bankruptcy, nonestate makes it
    difficult to assess the classification and collectibility of
    installment agreement, and older cases.  Weaknesses will likely
    unpaid assessments.
    continue in this area until further corrective action is taken.
    (continued) 10Unpaid assessments consist of amounts for which (1)
    IRS can support the existence of a receivable through taxpayer
    agreement or a favorable court ruling (federal taxes receivable),
    (2) neither the taxpayer nor the court has affirmed that the
    amounts are owed (compliance assessments), and (3) IRS does not
    expect further collections due to factors such as the taxpayer's
    death, bankruptcy, or insolvency (write-offs). Page 6
    GAO/AIMD-99-193  IRS Custodial Financial Management Weaknesses B-
    282731 Internal control/compliance issues and effects
    IRS actions to address issues Newly reported issuesa Issue:
    Delays are occurring in posting trust fund recovery penalty  IRS
    action: IRS has not identified plans to address this issue. tax
    assessments to taxpayer accounts.
    GAO response:  We will follow-up on this issue as part of our
    audit Effect: Such delays have resulted in refunds being issued to
    of IRS' fiscal year 1999 financial statements. taxpayers that have
    an outstanding tax liability. Issue:  IRS does not ensure that
    installment agreements with                  IRS action: IRS
    issued a memorandum and guidance for revenue taxpayers fully
    satisfy outstanding tax liabilities.
    officers to reiterate that new installment agreements must fully
    satisfy the tax liability. Effect: IRS is not in compliance with
    the Internal Revenue Code,              GAO response: We will
    follow-up on this issue as part of our audit Section 6159.
    of IRS' fiscal year 1999 financial statements. aThese consist of
    internal control or compliance issues first reported in our report
    on IRS' fiscal year 1998 financial statements, see GAO/AIMD-99-75,
    March 1, 1999. As the table shows, problems in managing and
    reporting unpaid assessments are pervasive.  Typically, an
    entity's accounts receivable balances would be supported by
    detailed records, listings, or a subsidiary ledger of individual
    amounts.  To compensate for the lack of an unpaid assessment
    subsidiary ledger, IRS uses ad hoc programs that extract data from
    the tax master files-its database of taxpayer information.  These
    programs classify such assessments into the three categories
    needed for financial reporting: taxes receivable, compliance
    assessments, and write-offs.  However, as in past years, the
    results still required significant adjustments totaling tens of
    billions of dollars before taxes receivable could be reliably
    reported on the balance sheet.11  This is due in part to the fact
    that, lacking detailed records, IRS can only determine the amounts
    for each category by projecting the results of a statistical
    sample of its unpaid assessments.  Figure 1 shows the level of
    adjustments needed in fiscal year 1998 to arrive at reliable,
    auditable amounts for each category of unpaid assessments.  Until
    IRS makes significant improvements in its systems, large
    adjustments will continue to be necessary to properly classify
    unpaid assessments due to IRS' reliance on ad hoc procedures and
    projections. 11In accordance with Statement of Federal Financial
    Accounting Standards (SSFAS) No. 7, taxes receivable is the only
    category of unpaid assessments that is included on the balance
    sheet. Page 7                     GAO/AIMD-99-193  IRS Custodial
    Financial Management Weaknesses B-282731 Figure 1:  Comparison of
    Unpaid Assessments Before and After Audit Adjustments as of
    September 30, 1998 Billions of Dollars 119 120       110 100 81
    83 80 60                            54 40 22 20 0 Taxes
    Compliance           Write-offs receivable Before Audit
    Adjustments After Audit Adjustments Note:  The adjusted balance of
    taxes receivable presented represents the gross taxes receivable
    (does not include the allowance for doubtful accounts).  Also note
    that the total unadjusted unpaid assessment balance of $247
    billion reflected in this figure was adjusted to $222 billion, due
    primarily to duplicate assessments and errors. Source:  IRS master
    files and IRS fiscal year 1998 financial statements. The
    subsidiary ledger weakness is particularly illustrative of the
    need to make changes, because it continues to have direct
    consequences on taxpayers.  The consequences we identified
    primarily involved a type of assessment called a trust fund
    recovery penalty (TFRP) assessment.  This assessment occurs when a
    business does not pay IRS the payroll taxes12 that have been
    withheld "in trust" on behalf of the federal government from
    employee wages.  Each officer of a business can be individually
    liable for the amounts withheld from employees, provided the
    officers are found willful and responsible for the nonpayment of
    these taxes.  To collect these 12Payroll tax withholdings are
    comprised of individual income tax withholdings and employer and
    employee withholdings for the Federal Insurance Contribution Act
    (FICA), which include Social Security and Hospital Insurance
    taxes. Page 8                     GAO/AIMD-99-193  IRS Custodial
    Financial Management Weaknesses B-282731 taxes, IRS can assess
    several business officers individually for the amounts withheld
    from employees but not paid to the government.  However, while
    these trust fund recovery penalty assessments can be recorded
    against several officers in addition to maintaining the original
    taxes owed by the business, IRS can collect the amount owed only
    once. In our fiscal year 1997 audit, we reported that TFRP
    payments were not accurately recorded to reflect each responsible
    party's tax liability reduction in more than half of the cases we
    reviewed.  In some cases, this resulted in the withholding of
    refunds due to certain taxpayers and liens remaining on taxpayers'
    personal properties even though the liabilities had already been
    paid in full.  Similarly, we found in this year's audit that in 56
    of 106 cases (53 percent) reviewed involving TFRP assessments for
    unpaid payroll and excise tax withholdings, payments were not
    accurately recorded to reflect each responsible party's tax
    liability reduction. Conversely, we also found for fiscal year
    1998 that delays in posting the TFRP assessments to all the
    related parties resulted in refunds being issued to taxpayers
    before they could be offset against amounts owed.   We found
    instances where such assessments were not made for several years.
    For example, in one case, an officer of a bankrupt business-who
    was also later found liable for a portion of the business's unpaid
    payroll taxes- received two refunds totaling almost $10,000 during
    the first 38 months after the business defaulted on its payroll
    taxes.  This occurred because the officer was not assessed for the
    employee portion of the unpaid payroll taxes until 40 months after
    the taxes were first due.  In another case, the officers of a
    bankrupt business were not assessed a TFRP until 54 months after
    the first period in which the payroll taxes were due.  Refunds
    issued to two officers totaling almost $4,000 were issued 48
    months after the business defaulted on its payroll taxes.  These
    refunds could have been offset against outstanding tax liabilities
    if IRS had more quickly identified and recorded these TFRP
    assessments to the taxpayers' accounts. For the weaknesses we
    previously identified, IRS has taken some corrective actions and
    other actions are planned.13  For example, we noted some
    improvements in the documentation supporting its unpaid
    assessments and in its ad hoc computer programs for extracting
    master file data for the financial statements.  However,
    improvements in other areas 13See appendix II for a specific list
    of all pertinent recommendations from previous audits and the
    status of IRS' actions to address them, i.e., recommendations 2
    through 8. Page 9                     GAO/AIMD-99-193  IRS
    Custodial Financial Management Weaknesses B-282731 will not occur
    for many years.  Specifically, significant improvements will not
    be possible until a subsidiary ledger with appropriate links
    between related TFRP assessments and payments is established, an
    action IRS currently has no firm plans to implement.  Our work
    showed that over 185,000 taxpayers have 237,000 TFRP assessments
    and that over 50 percent of TFRP cases reviewed had errors in
    crediting payments for related accounts.  Until IRS can greatly
    improve the accuracy of its individual unpaid assessments, many
    taxpayers will continue to be vulnerable to unwarranted collection
    actions.  In addition, the government will continue to be
    vulnerable to a preventable loss of revenue from issuing refunds
    to taxpayers that owe taxes.  As noted in a prior GAO report,14
    the significance and magnitude of this problem requires interim
    solutions to address these issues, even if such solutions require
    manual procedures, such as manually cross-linking taxpayer data.
    Our fiscal year 1998 audit also disclosed that IRS did not have
    procedures in place to ensure that installment agreements for
    repaying tax assessments provide for payment of the full amount of
    taxes due, as required by Section 6159 of the Internal Revenue
    Code.  Our detailed testing of 93 installment agreements showed
    that in 48 cases (52 percent), the installment agreement terms did
    not provide for the full payment of the taxes due prior to the end
    of the statutory collection period (generally 10 years).  In one
    case, the installment agreement required the taxpayer to pay $25 a
    month toward an outstanding tax liability of over $16 million.  At
    the end of the statutory collection period, such payments would
    have totaled $1,625, far less than 1 percent of the amount due.15
    In another instance, the installment agreement would result in
    repayment of $65,450 of a $1.5 million amount due (4 percent).
    IRS began addressing this weakness during fiscal year 1998, first
    by issuing a March 1998 memorandum reiterating that under any new
    installment agreement, the taxpayer must fully satisfy the tax
    liability, and second by issuing new guidelines in August 1998.
    However, IRS does not have monitoring procedures in place to
    ensure that the new guidelines are being followed across the
    country.  We will assess the success of these corrective actions
    during our fiscal year 1999 audit.16 14GAO/AIMD-99-16, October 30,
    1998. 15The amount due includes the original tax liability plus
    penalties and interest. 16Previous recommendations related to
    unpaid assessments are listed in appendix II, recommendations 2
    and 5 through 8. Page 10                    GAO/AIMD-99-193  IRS
    Custodial Financial Management Weaknesses B-282731 Recommendations
    To address delays in posting trust fund recovery penalty
    assessments, we recommend that IRS analyze and determine the
    factors causing delays in processing and posting all such
    assessments.  Once these factors have been determined, we
    recommend that IRS develop procedures to reduce the impact of
    these factors to ensure timely posting to all applicable accounts
    and proper offsetting of refunds against unpaid TFRP assessments
    before issuance. To ensure compliance with Section 6159 of the
    Internal Revenue Code, we recommend that IRS identify and
    institute procedures to monitor compliance of installment
    agreements.  Such monitoring should ensure that the installment
    agreements provide for full payment of the taxes owed. For
    example, management could randomly select installment agreements
    from all of its units to review for compliance with the code.
    Inadequate Controls              As we have previously reported,
    IRS' controls over cash, checks, and Over Manual Tax
    related hard-copy taxpayer data it receives from taxpayers are not
    adequate.  We recognize that because receipts and taxpayer data
    are Receipts and Taxpayer  inherently vulnerable, some thefts are
    inevitable.  However, while IRS has Information
    made some improvements, further actions and policy changes are
    needed to mitigate risks.  In addition, consistent implementation
    of new and existing policies will require regular headquarters
    follow-up and monitoring.  We previously reported our findings in
    this area with regard to several service centers and district
    offices visited, but we have subsequently identified similar
    conditions in varying degrees at all 10 service centers,
    additional district offices, IRS post-of-duty offices, and at
    commercial lockbox banks. The pervasiveness and sensitivity of
    this condition emphasizes the need for IRS to act quickly and
    aggressively to properly safeguard assets and protect taxpayer
    data.  The potential for loss and taxpayer burden can be seen in
    the number of employee theft-related investigations opened by IRS
    in fiscal years 1997 and 1998-specifically, 56 cases involving
    actual or alleged theft of about $1 million in receipts at IRS
    field offices and lockbox banks, and another 100 cases in which
    the amount was not quantified.  Because some thefts have likely
    gone unidentified or undetected, actual losses may be much
    greater.  Table 2 summarizes the weaknesses we identified in this
    area, both in the past and in our most recent work with their
    effects and IRS' actions to address these issues. Page 11
    GAO/AIMD-99-193  IRS Custodial Financial Management Weaknesses B-
    282731 Table 2:  Internal Control Issues Related to Manual
    Receipts and Taxpayer Data Internal control issues and effects
    IRS actions to address issues Issues previously reported Issue:
    Service centers had insufficient controls to deter employee  IRS
    actions: IRS is studying potential deterrents. While some theft of
    receipts and data in receipt processing areas.  For example,
    service centers have lockers for receipt-processing staff to store
    there were no surveillance cameras and employees were allowed
    personal items, IRS is currently conducting space feasibility
    studies to bring in personal belongings such as purses and
    lunchboxes that  at others.  According to IRS, based on the
    results of the feasibility could be used to conceal receipts.
    studies, a plan will be initiated by December 1999. Effect: Such
    weaknesses increase the exposure of IRS and              GAO
    response:  IRS continues to lack surveillance cameras in its
    taxpayers to loss or theft.
    receipt processing areas and the availability of lockers and
    enforcement of their use is inconsistent. Issue:  Mail containing
    cash and checks was received and opened  IRS actions: IRS issued a
    policy in November 1998 to require all outside controlled areas.
    mail, except confidential mail, to be routed through the receipt
    processing function. Effect:  Uncontrolled areas are more
    vulnerable to loss or theft of  GAO response: Follow-up is planned
    for fiscal year 1999. receipts and taxpayer data. Issue: Tax
    payments were received by personnel, such as security  IRS
    actions: IRS issued a policy in December 1998 requiring that
    guards, that are not authorized to accept payments.
    service center deposit units be contacted when security guards and
    unauthorized personnel are approached by taxpayers with Effect:
    Receipts are vulnerable to theft or loss.
    payments. GAO response:  Based on our visits to service centers,
    security guards and other unauthorized personnel do not accept
    payments. Issue:  Delays in obtaining fingerprint and background
    information  IRS actions: IRS purchased and installed 27
    fingerprinting on IRS employees allowed staff with previous
    convictions, and         machines compatible with FBI's systems
    and expects FBI to fully unsuitable backgrounds, to process
    taxpayer receipts and data.        implement the system by July
    1999.  IRS expects the fingerprint system to improve the
    timeliness of fingerprint results.  It expects to Effect: Receipts
    and taxpayer data are at unnecessary risk of theft. have these
    measures in place for the 2000 filing season. GAO response: In
    April 1999, we visited some sites and saw that the new
    fingerprinting machines had been installed.  We will perform
    further follow-up for fiscal year 1999 to determine whether IRS
    has fully interfaced its fingerprinting machines with the FBI's
    system. Issue:  Daily deposits, which may total hundreds of
    millions of       IRS actions: IRS issued a directive in April
    1999 that requires dollars, are transported to banks via unarmed,
    unescorted couriers  offices to use bonded couriers with locked,
    enclosed vehicles to in unsecured vehicles and on bicycles.
    deliver tax receipts.  IRS reported it is also upgrading service
    center requirements to include the use of armed couriers and plans
    to Effect:  Such security does not adequately protect deposits and
    have all field offices send tax receipts by overnight mail to
    sensitive taxpayer data from theft while in transit.
    designated service centers by August 1999. GAO response: Follow-up
    was performed in April 1999.  Although this new policy was issued,
    we found that it had not been fully implemented.  We will perform
    additional follow-up for the fiscal year 1999 financial statement
    audit. (continued) Page 12                GAO/AIMD-99-193  IRS
    Custodial Financial Management Weaknesses B-282731 Internal
    control issues and effects
    IRS actions to address issues Issue:  Service centers and district
    offices stored receipts and             IRS actions: IRS is
    developing plans to address most of these taxpayer data in
    unsecured areas or in open containers.
    issues, such as (1) ensuring that each service center has
    appropriate containers to secure unmatched checks by August
    Effect:  IRS and taxpayers are exposed to potential losses and
    1999 and (2) developing guidelines requiring district offices to
    fraud.
    maintain receipts in locked containers. GAO response: Follow-up is
    planned for fiscal year 1999. Newly reported issues Issue:
    Inadequate internal controls similar to those previously
    IRS actions: IRS has issued a new policy regarding the identified
    were also found at post-of-duty offices, such as storage of
    safeguarding of receipts at district and post-of-duty offices.
    receipts and taxpayer data in unsecured areas or in open
    containers.
    GAO response: Follow-up was performed in April 1999.  Although
    this new policy was issued, we found that it had not been fully
    Effect:  IRS and taxpayers are exposed to potential losses and
    implemented.  We will perform additional follow-up for the fiscal
    fraud.
    year 1999 financial statement audit. Issue:  Inadequate internal
    controls similar to those previously             IRS actions: IRS
    has not yet reported plans to address lockbox identified were also
    found at lockbox banks, including use of                banks.
    unarmed, unsecured couriers for transporting checks and taxpayer
    data, and receipt processing staff starting work prior to
    completion of fingerprint or background checks. Effect:  IRS and
    taxpayers are exposed to potential losses and fraud. Issue:
    Additional weaknesses were identified related to courier
    IRS actions:  As discussed above, IRS issued a directive in April
    security.  For example, one service center included cash in its
    1999 regarding improvements to be made to courier security.
    deposits and one post-of-duty office used an IRS employee to
    deliver its receipts with no audit trail to track that the
    receipts were deposited.  Also, deposits at one district office
    were transported on foot. Effect:  IRS and taxpayers are exposed
    to potential losses and fraud. Issue: IRS' procedures for
    accepting walk-in payments at service  IRS actions: IRS has not
    yet reported plans to address these centers do not adequately
    protect taxpayer receipts and data from  issues. loss.  Generally
    receipts are not prepared and provided to taxpayers and payments
    are not logged in to ensure completeness of receipts and to
    reconcile to deposits. Effect: IRS and taxpayers are exposed to
    potential theft or loss. Issue: Scope of background checks
    required of lockbox employees  IRS actions: IRS has not yet
    reported plans to address these was inconsistent and less than
    that required of IRS employees.               issues. Effect: IRS
    and taxpayers are exposed to potential theft or loss. Issue:  One
    district office staff was unaware of fingerprinting
    IRS actions:  According to IRS district office management, all
    staff requirements for applicants.  As a result, some temporary
    involved with fingerprint and background checks were informed of
    employees were hired without fingerprint checks.
    correct procedures. Effect: IRS and taxpayers are exposed to
    potential theft or loss.            GAO response: Follow-up is
    planned for fiscal year 1999. Issue:  Employees at one post-of-
    duty office were not aware of               IRS actions:
    According to IRS post-of-duty management, requirement to overstamp
    checks made out to "IRS" or were not                responsible
    employees were reminded of the policy. doing so promptly.
    GAO response: Follow-up is planned for fiscal year 1999. Effect:
    IRS and taxpayers are exposed to potential theft or loss. Page 13
    GAO/AIMD-99-193  IRS Custodial Financial Management Weaknesses B-
    282731 Many of our findings in this area stem from our fiscal year
    1997 audit work. We subsequently identified additional findings
    during a review of controls over receipts and taxpayer data at
    selected service centers and district offices during the April
    1998 peak filing season.  We issued a separate report17 on these
    latter findings in November 1998.  However, additional testing we
    conducted to complete our fiscal year 1998 audit, as well as work
    performed as part of our ongoing fiscal year 1999 financial audit,
    showed that more weaknesses existed at other service centers,
    district and post-of-duty offices, and lockbox banks.  These
    weaknesses increase the vulnerability of receipts and taxpayer
    information to theft, fraud, or loss to both taxpayers and the
    government.  Specifically, we have identified the following
    weaknesses relating to background checks at IRS offices and
    lockbox banks. * In at least six service centers, delays in
    background investigations resulted in employees being hired and
    processing receipts and taxpayer data before the results of their
    fingerprint/background checks were completed. According to IRS, at
    four of these service centers, background check results disclosed
    that 273 (5 percent) of about 5,400 employees hired to handle
    taxpayer data and/or receipts had falsified key information on
    their applications.  Of the 273 employees, 64 (23 percent) had
    significant unsuitable backgrounds, such as criminal convictions,
    which resulted in their termination or forced resignation. As late
    as March 1999, background investigations were pending on some
    employees hired in fiscal year 1998 and still working for IRS-over
    5 months after the end of the fiscal year.  Similarly, temporary
    employees at lockbox banks were also hired and handling receipts
    and taxpayer data before the results of their background or
    fingerprint checks were received. * At one district office, one
    staff responsible for fingerprint checks was not aware that IRS
    requires temporary employees to be fingerprinted. As a result, 14
    temporary employees hired during fiscal year 1999 were not
    initially fingerprinted. * At lockbox banks, we found that the
    scope of background checks required of lockbox employees was
    inconsistent among the banks and was less than that required of
    IRS employees.  For example, one lockbox bank performed background
    checks that encompassed only the county in which the temporary
    employees currently reside while at another lockbox bank, the
    scope of background checks for temporary 17GAO/AIMD-99-15,
    November 30, 1998. Page 14                 GAO/AIMD-99-193  IRS
    Custodial Financial Management Weaknesses B-282731 employees
    included the entire state.  In contrast, IRS temporary employees
    are subject to nationwide  background checks.  We found that this
    inconsistency was due to ambiguous language contained in the
    standard statement of work for the lockbox banks regarding
    background checks for employees, which was thus subject to
    differing interpretations by the banks. Another pervasive control
    weakness was the inadequate security over deposits and taxpayer
    data transported to banks and service centers.  In our earlier
    report on conditions during the peak period of the 1998 filing
    season, we reported that at four service centers we visited,
    unarmed couriers working alone picked up deposits-$100 million to
    $200 million twice a day-for transporting to a bank for deposit.
    Some of these deposits were left in unsecured, unattended
    vehicles.  Subsequent audit work identified similar weaknesses at
    additional locations.  For example, * At one service center, the
    courier did not have credentials identifying him as the authorized
    courier.  He picked up receipts that included cash18 and drove off
    in a car with family members who were not authorized to pick up
    receipts. * At a district office, one courier picked up the
    deposit and walked a block away to await the arrival of a second
    courier.  During our observation, the courier waited 20 minutes
    for the second courier to arrive and, for a time, was joined by
    another individual.  When the second courier arrived in a marked
    courier company truck, the first courier handed him the deposit
    for delivery to the bank.  IRS did not oversee this transfer to
    the second courier, nor was the transfer documented.  When the
    second courier delivered the deposit, the receipt provided by the
    bank did not document the amount of the deposit nor any other
    identifying information to enable IRS to verify the bank received
    the deposit intact.  According to IRS, the district's deposits
    average about $500,000 to $1 million per day during the nonpeak
    season. * At another district office, a deposit of $4.5 million
    was handed by IRS to a courier who walked the deposit two blocks
    to where his bicycle was parked.  The courier then waited for
    about 20 minutes for another courier driving an unmarked pickup
    truck.  The first courier loaded his bicycle onto the truck and
    waited in the truck with the deposit until the 18Other service
    centers we visited converted cash to a cashier's check before
    preparing the deposit or used an armored courier to transfer cash
    deposits. Page 15                   GAO/AIMD-99-193  IRS Custodial
    Financial Management Weaknesses B-282731 second courier returned
    from briefly delivering a package.  The two couriers then
    departed.  According to the bicycle courier, the second courier
    later stopped to let him out of the truck and then proceeded to
    the bank with the IRS deposit. * At one lockbox bank, a substitute
    courier who did not wear a uniform, was unknown by bank staff, and
    who did not present or display any identification, was able to
    bypass several layers of security to obtain unescorted access to
    the receipt processing area.  Within this area, the courier was
    allowed to load boxes of mail containing taxpayer returns destined
    for an IRS service center without being questioned or asked for
    identification. Additional weaknesses or problems we identified
    include the following. * At some district and post-of-duty offices
    we visited, receipts and taxpayer information received by revenue
    officers and examiners were kept in open containers or in unlocked
    file cabinets in the customer service walk-in work area, easily
    accessible to unauthorized employees and in some instances, to the
    general public. * At one post-of-duty office, checks made out to
    "I.R.S." were not overstamped with "Internal Revenue Service" or
    "United States Treasury" to prevent alteration.  IRS staff were
    either not aware of this requirement or were not performing it
    promptly. For those control weaknesses identified in earlier
    reports, we made recommendations that IRS generally agreed with
    and has either implemented or made plans to implement.  For
    example, IRS recently issued a policy prohibiting guards and other
    unauthorized personnel from receiving payments.  However, the new
    policy does not require that more than one person receive walk-in
    payments and, except for cash, does not require that receipts be
    logged.  Also, IRS only requires service center staff to provide
    receipts to taxpayers making walk-in payments by cash, not for
    check or money order payments.  In addition, IRS does not post
    signs informing taxpayers to request receipts.  We will be
    following up during our fiscal year 1999 audit on additional
    actions IRS is taking to address our recommendations.19 19Previous
    recommendations and IRS' actions to date related to physical
    security over manual tax receipts and taxpayer information are
    listed in appendix II, recommendations 9 through12 and 20 through
    35. Page 16                  GAO/AIMD-99-193  IRS Custodial
    Financial Management Weaknesses B-282731 IRS has also taken other
    steps to improve controls over receipts and taxpayer data. As we
    reported last year, in one scheme, a check made out to "IRS" was
    altered to a fraudulent payee-"I. R. Smith."20  For the 1999 tax
    filing season, IRS revised its form 1040 instructions to instruct
    taxpayers to make tax payment checks payable to "United States
    Treasury."  This change in payee should reduce IRS' vulnerability
    to stolen checks being altered.  To further prevent fraud and
    theft, IRS has purchased and installed fingerprinting machines
    compatible with FBI's system at 17 sites including all 10 service
    centers and 7 other IRS offices.  According to IRS officials, the
    system is expected to improve turnaround time for fingerprint
    checks. These same officials stated that IRS is waiting for the
    FBI to complete the implementation of the system by July 1999.
    Recommendations    To address weaknesses in controls over taxpayer
    data and receipts at IRS district offices and posts-of-duty, we
    recommend that IRS expand the current review of service center
    deterrent controls to include similar reviews of controls at IRS
    district offices and posts-of-duty in areas such as courier
    security, safeguarding of receipts in locked containers,
    requirements for fingerprinting employees and requirements for
    promptly over-stamping checks made out to "IRS" with "Internal
    Revenue Service" or "United States Treasury." Based on the
    results, IRS should make appropriate changes to strengthen its
    controls at these locations. To improve controls at IRS lockbox
    banks, we recommend that IRS work with Treasury's Financial
    Management Service (FMS) to revise the current lockbox contracts
    to specifically require that: * background checks be completed
    before employees begin working; * temporary employees be subjected
    to background checks that are consistent with those required of
    IRS employees; and * taxpayer data and receipts in transit from
    the lockbox banks are appropriately protected. To reduce the
    vulnerability of walk-in payments to being lost or stolen, we
    recommend that IRS require service center staff to provide
    receipts to all walk-in taxpayers regardless of the method of
    payment.  In addition, IRS should post signs reminding taxpayers
    to request receipts.  At service centers not normally equipped to
    receive walk-in payments, all receipts 20GAO/AIMD-99-16, October
    30, 1998. Page 17                 GAO/AIMD-99-193  IRS Custodial
    Financial Management Weaknesses B-282731 should be logged in to
    ensure completeness and accuracy of receipts and deposits. Weak
    Preventive                                 We recognize that the
    high volume and nature of refund activity makes it Controls Over
    Refunds  impossible to completely eliminate the risk that
    inappropriate refunds are issued.  However, IRS continues to lack
    adequate preventive controls to and Earned Income
    mitigate the risk of inappropriate refund payments.  In addition,
    earned Tax Credits Increase                            income tax
    credits (EITC) continue to be vulnerable to high rates of invalid
    Risk of Inappropriate                           claims. Although
    IRS has detective (postrefund) controls in place, the lack of
    adequate preventive controls over these areas unduly exposes the
    Payments                                        government to
    potentially significant losses if refunds are made inappropriately
    or revenue owed the government is inappropriately reduced by
    invalid claims.  Table 3 summarizes the weaknesses we identified
    related to refund processing controls, along with their effects
    and IRS' actions to address these issues. Table 3:  Internal
    Control Issues Related to Refunds and Earned Income Tax Credit
    Claims Internal control issues and effects
    IRS actions to address issues Issues previously reported Issue:
    IRS does not compare tax returns with W-2 and other third  IRS
    action: IRS has not performed a cost-benefit analysis of party
    data at time of filing and instead relies on a comparison
    manually comparing W-2 and other third party information to tax
    several months later to detect differences.
    returns at the time the returns are received. According to IRS,
    plans to automate this comparison at the time of filing would
    require Effect:  This has resulted in the issuance of
    inappropriate refunds  changes to the tax code and tax document
    filing process.a or in reduced revenue to the government.
    GAO response: The capability to perform an automated comparison is
    still years away.  As we previously recommended, IRS should
    perform a comprehensive cost-benefit analysis to better determine
    the actual costs and benefits of implementing preventive controls
    in the short term. Issue:  Gaps in internal controls between IRS'
    manual and           IRS action: IRS has plans to automate its
    process for identifying automated refund processing systems
    allowed duplicate refunds to  and preventing potential duplicate
    refunds which it expects to be paid.
    complete in mid-1999. Effect: Such weaknesses resulted in
    inappropriate refunds and       GAO response: We will follow up on
    this issue as part of our audit thus, financial losses to the
    government.                           of IRS' fiscal year 1999
    financial statements. (continued) Page 18              GAO/AIMD-
    99-193  IRS Custodial Financial Management Weaknesses B-282731
    Internal control issues and effects
    IRS actions to address issues Issue: EITCs are vulnerable to high
    rates of invalid claims.  An IRS  IRS action: IRS started a 5-year
    compliance initiative to minimize review of 290,000 tax returns
    with indications of errors or               losses in this area.
    This initiative is intended to increase taxpayer irregularities
    found that $448 million of the $662 million in EITC
    awareness, strengthen enforcement of EITC requirements, and claims
    (68 percent) were invalid.
    research sources of EITC noncompliance. Effect:  Invalid EITC
    claims may result in reduced revenue to the         GAO response:
    We will follow up on this issue as part of our audit government or
    inappropriate refunds being issued.                         of
    IRS' fiscal year 1999 financial statements. aAction Plan for GAO
    Recommendations, A Report to Congress: The Internal Revenue
    Service's Plans for Implementing Financial Statement Audit
    Recommendations Made by the General Accounting Office, dated
    January 8, 1999. Note:  Weaknesses in controls over refunds
    resulting from delays in posting trust fund recovery penalty
    assessments were discussed previously in this report under unpaid
    assessment issues.  (See table 1.) Our recent work confirmed
    continuing weaknesses were present in IRS procedures and systems
    for issuing refunds to taxpayers.  For example, gaps in controls
    between IRS' automated and manual systems continue to make IRS
    vulnerable to issuing duplicate refunds.  In fact, we noted
    several cases in which IRS procedures failed to prevent refunds
    from being paid twiceone claim that was processed manually and one
    processed through IRS' automated system.  We also found instances
    where delays in posting assessments resulted in IRS issuing
    refunds to taxpayers that had unpaid tax assessments. Correcting
    these internal control weaknesses as quickly as possible is
    important because until they are corrected, the government's
    exposure to fraud and financial losses is increased.  For example,
    IRS identified over $17 million in fraudulent refunds that had
    been issued during the first 9 months of calendar year 1998.21
    However, the full magnitude of fraudulent and other inappropriate
    refunds is unknown.  As we reported last year, significant levels
    of invalid EITC claims further magnify the control weaknesses over
    refunds.22  Most of IRS' efforts under its 5-year compliance study
    to minimize losses from EITC claims have not progressed far enough
    to make any judgment about their effectiveness. Therefore, we will
    continue to monitor IRS' progress in resolving these issues during
    our fiscal year 1999 audit.23 21IRS was unable to provide
    information on the extent to which these fraudulent refunds were
    recovered. 22GAO/AIMD-98-77, February 26, 1998. 23Previous
    recommendations related to refunds are listed in appendix II,
    recommendations 13 through14. Page 19                   GAO/AIMD-
    99-193  IRS Custodial Financial Management Weaknesses B-282731
    IRS' Revenue                     IRS continues to be unable to
    routinely track and report how much revenue Reporting and
    has been collected for Social Security, Hospital Insurance, and
    individual income taxes-three of the federal government's four
    largest revenue Distribution Process             sources.  Also,
    IRS is unable to timely report how much revenue has been Continues
    to Be                  collected for the Highway Trust Fund and
    other excise tax-related trust Inadequate and Prone  funds.  This
    condition exists because the accounting information needed to
    validate the taxpayer's liability and record the payment to the
    proper trust to Error                         fund is provided on
    the tax return, which is received months after the payment is
    submitted rather than at the time of payment.  Further, the
    information on the return pertains only to the amount of the tax
    liability, not the distribution of amounts previously collected.
    This condition presents a number of reporting limitations with
    respect to Social Security and Hospital Insurance taxes.  For
    example, payroll taxes collected on behalf of the federal
    government are deposited in the general revenue fund of the
    Department of Treasury, from which they are subsequently
    distributed to the appropriate trust funds.  This distribution is
    based on employee wage information certified by the Commissioner
    of the Social Security Administration (SSA), not on amounts
    actually collected for payroll taxes.  To the extent that annual
    payroll tax collections are less than the actual tax liabilities,
    the government's general revenue fund subsidizes the Social
    Security and Hospital Insurance trust funds.  The annual amount of
    this subsidy is unknown because IRS cannot determine the specific
    amount of revenue it actually collects for Social Security and
    Hospital Insurance taxes.24  Having the capability to report
    actual collections of significant taxes such as Social Security
    would enable IRS to report information useful to interested
    parties including the Congress. IRS' inability to timely track and
    report how much revenue has been collected for excise tax-related
    trust funds also presents operational issues for IRS and Treasury
    in the distribution of excise tax receipts to these trust funds.
    Because data are not available to allocate excise taxes to the
    appropriate trust funds when deposits are made, the Department of
    the Treasury uses a process that is complex, cumbersome, and prone
    to error in order to distribute excise tax receipts to the
    respective trust funds. 24As of September 30, 1998, the estimated
    amount of unpaid taxes and interest in IRS' unpaid assessments
    balance was approximately $38 billion for Social Security and
    Hospital Insurance.  While these totals do not include amounts no
    longer in the unpaid assessments balance due to the expiration of
    the statutory collection period, they nevertheless give an
    indication of the cumulative amount of the subsidy provided from
    the general fund. Page 20                   GAO/AIMD-99-193  IRS
    Custodial Financial Management Weaknesses B-282731 Table 4
    summarizes the problems we identified in this area, both in the
    past and in our most recent work, together with the effect and
    IRS' actions to address these issues. Table 4:  Internal Control
    and Compliance Issues Related to Revenue Reporting and
    Distribution Internal control/compliance issues and effects
    IRS actions to address issues Issues previously reported Issue:
    IRS is unable to routinely track and report actual revenue
    IRS actions: IRS recently completed a study of the capabilities to
    collected for specific trust funds and individual income taxes.
    capture specific tax type/fee code information and is currently
    analyzing the study's results. Effect:  IRS must go through a
    complex process to determine               GAO response: We will
    follow up on this issue as part of our audit (certify) the amounts
    that should be distributed to the excise tax        of IRS' fiscal
    year 1999 financial statements. trust funds, and cannot separately
    report the amount of revenue collected for Social Security,
    Hospital Insurance, and individual income taxes. Issue:  IRS
    certified amounts to be distributed to excise tax trust       IRS
    actions: IRS developed a method to allocate excise tax funds based
    on assessments rather than actual taxes collected.
    collections to specific excise taxes and began using this
    methodology in June 1998. Effect: IRS' certification process did
    not comply with specific           GAO response: The allocation
    method now complies with the provisions of the law until June
    1998.                                    legal requirements;
    however, we found it is still prone to error. Issue:  IRS lacked
    adequate controls over the excise tax                  IRS
    actions: IRS has actions either planned, in process, or
    certification process to detect taxpayer errors, data input
    errors, and  implemented to address most of these issues. errors
    in preparing the certification.
    GAO response: We will follow up on this issue as part of our audit
    Effect:  Excise tax trust funds may not receive the appropriate
    of IRS' fiscal year 1999 financial statements. amount of excise
    tax revenue. Newly reported issues Issue: IRS' controls did not
    always ensure that tax returns were          IRS actions: IRS is
    determining the cause for posting delays and recorded timely.
    plans to establish additional internal controls once the cause is
    determined. Effect: The amounts initially distributed to excise
    tax-related trust     GAO response: We will follow up on this
    issue as part of our audit funds may not be timely adjusted
    through IRS' certification process. of IRS' fiscal year 1999
    financial statements. Although IRS has taken some action, problems
    remain in the excise tax area.  For example, IRS developed a
    method to allocate payments to specific excise taxes based on the
    related records of payments received and the subsequently provided
    tax returns.  While this method allows IRS to comply with the law
    for certifying excise taxes based on collections, IRS continues to
    have difficulties certifying the amounts to be distributed to the
    excise tax-related trust funds.  Our fiscal year 1998 audit
    continued to identify fundamental internal control weaknesses over
    this process. For example, the new certification process allowed
    some errors to remain undetected.  Such errors included taxpayer
    errors made in preparing excise Page 21                  GAO/AIMD-
    99-193  IRS Custodial Financial Management Weaknesses B-282731 tax
    returns that were not detected and corrected by IRS when
    processing the returns, IRS errors in inputting excise tax
    information to its master files, and IRS erroneous omissions of
    amounts from the quarterly certification that should have been
    distributed to the trust funds.  In the latter case, IRS
    inappropriately subtracted certain amounts of all excise tax types
    from the certification process for the quarter ended December 31,
    1997, and, as a result, understated the amounts to be distributed
    to all trust funds.  We identified the amounts understated for
    three trust funds: the Highway Trust Fund (understated by $92
    million), Airport and Airways Trust Fund ($57 million), and Black
    Lung Disability Trust Fund ($3 million). These errors occurred
    even though there was evidence of supervisory review of the data
    on the related certification documentation.  Upon bringing these
    errors to IRS' attention, they were corrected. Delays in posting
    tax returns also resulted in misstatements of amounts certified.
    Because specific tax type data are not available to allocate
    excise taxes to the appropriate trust funds when deposits are
    made, Treasury uses a process to estimate the initial distribution
    of excise taxes.  This process involves the use of economic models
    prepared by the Office of Tax Analysis to estimate the initial
    distribution of tax receipts. FMS uses these estimates to prepare
    entries for the initial distribution to the trust funds, which are
    then recorded by the Bureau of Public Debt (BPD) in the books and
    records of the trust funds maintained by the Treasury.  After the
    initial distribution, IRS certifies quarterly the amounts that
    should have been distributed to the excise tax-related trust funds
    using its records of payments received and the subsequently
    provided tax returns.  FMS uses these certifications to prepare
    adjustments to the initial trust fund distributions, which are
    then recorded by BPD.  However, in one quarter, we found that IRS
    did not record all tax returns in time to include them in the
    quarterly certification of the amounts that should be distributed
    to the various funds.  The amount IRS certified to the Highway
    Trust Fund for the quarter ended June 30, 1998, included
    approximately $590 million that was related to excise tax returns
    from the previous quarter.  IRS officials could not explain why
    this occurred, but they identified at least one high-dollar tax
    return which was not recorded in time to be included in the
    certification for the quarter ended March 31, 1998.  Although the
    misstatement was corrected the following quarter (when the tax
    return was recorded), the condition demonstrates that IRS'
    certification process does not ensure that amounts distributed to
    excise tax-related trust funds are timely adjusted. Page 22
    GAO/AIMD-99-193  IRS Custodial Financial Management Weaknesses B-
    282731 As long as IRS lacks the data to identify the specific
    amount of revenue received for each tax type at the time of
    payment, IRS, Treasury, and excise tax-related trust funds will
    continue to depend on a complex, error-prone process for
    determining revenue distributions.  We will follow up on the
    implementation and effectiveness of IRS actions as part of our
    fiscal year 1999 audit.25 Recommendation          To address
    delays in recording excise tax returns, we recommend that IRS
    establish procedures to ensure the prompt recording of tax
    returns.  IRS should implement controls to ensure that excise tax
    returns are recorded timely and included in the quarterly excise
    tax trust fund certifications. Financial Reporting     We
    continued to find that IRS' general ledger for custodial
    activities cannot Issues Remain           routinely generate
    reliable and timely financial information for decision-making.
    This is due to the fact that IRS' financial systems do not
    Unresolved              conform to the U.S. Government Standard
    General Ledger and subsidiary ledgers do not support material
    balances.  As a result of these weaknesses, IRS systems do not
    comply with the Federal Financial Management Improvement Act
    (FFMIA) of 1996, which requires that financial management systems
    comply with federal accounting and systems standards; these
    standards include the Standard General Ledger and subsidiary
    ledgers.  IRS' basic approach to preparing its annual custodial
    financial statements was designed specifically for the narrowly
    defined purpose of preparing auditable amounts and balances only
    at fiscal year-end.  This mechanism is not capable of producing
    reliable agencywide principal financial statements or financial
    performance information to measure results throughout the year as
    a management tool, which is a standard practice in private
    industry and some federal entities.  In addition, IRS' approach
    relies heavily upon ad hoc computer programming, which requires
    extensive technical expertise with IRS' master files-expertise
    that is possessed by only a limited number of individuals in IRS.
    Table 5 identifies general ledger internal control weaknesses and
    compliance issues we have identified, along with their effects and
    IRS' actions to address these issues. 25Previous recommendations
    related to IRS' revenue reporting and distribution process are
    listed in appendix II, recommendations 16 through 19. Page 23
    GAO/AIMD-99-193  IRS Custodial Financial Management Weaknesses B-
    282731 Table 5:  Internal Control and Compliance Issues Related to
    Financial Reporting Internal control/compliance issues and effects
    IRS actions to address issues Issues previously reported Issue:
    IRS' custodial general ledger system cannot routinely
    IRS action: IRS has planned a series of incremental steps to
    generate reliable and timely financial information for internal
    and          develop a system that can generate management reports
    and external users.
    financial statements beginning in 2000. Effect:  IRS must rely on
    costly, labor-intensive, and                       GAO response:
    Until IRS implements a proper general ledger time-consuming ad hoc
    programs to extract data requiring                     system that
    complies with federal requirements, it will continue to
    significant adjustments to prepare its annual financial
    statements.   rely on ad hoc procedures that severely limit its
    ability to obtain and Consequently, it cannot routinely generate
    periodic statements or            provide meaningful financial
    data routinely. other reliable information as a management tool.
    Issue:  IRS' custodial general ledger system does not comply with
    IRS action: IRS' systems modernization plan includes developing a
    Federal Financial Management System Requirements, federal
    new system that will meet requirements, but IRS currently does not
    accounting standards, and the U.S. Government Standard General
    estimate completion until 2009. Ledger.
    GAO response: IRS will not achieve compliance within the 3-year
    Effect:  IRS cannot rely on its custodial general ledger to
    support  time frame required.  We will continue to assess IRS'
    efforts to related amounts on the principal financial statements.
    address and correct this problem. Newly reported issues Issue:
    The use of interim ad hoc procedures to generate IRS'
    IRS action:  IRS has not yet developed plans to address this
    issue. custodial balances relies on extensive technical expertise
    with IRS' master files that is possessed by only a very limited
    number of individuals. Effect:  Should these individuals become
    unavailable for any reason, IRS would most likely be unable to
    prepare reliable custodial balances for its financial statements.
    As the table above indicates, correcting these problems will
    require IRS to make major changes to its financial systems, which
    is a long-term process. Sustained senior management attention to
    correcting the problems is important to ensure sound financial
    management for several reasons: * The general ledger system
    currently cannot properly report a reliable balance for taxes
    receivable nor can it report revenue receipts by specific tax
    type, such as the specific amounts collected for Federal Insurance
    Contributions Act (FICA)26 and individual income taxes, even
    though taxes receivable and revenue receipts are the two most
    significant components of IRS' financial statements.  Likewise, it
    cannot 26FICA taxes include both employer and employee
    contributions.  Based on information certified by IRS and the
    Social Security Administration, Treasury distributes FICA tax
    revenue-also referred to as social security taxes-to three
    specific trust funds established to finance the federal
    government's principal Social Security programs: the Federal Old
    Age and Survivors Insurance Trust Fund; the Federal Disability
    Insurance Trust Fund; and the Federal Hospital Insurance Trust
    Fund. Page 24                   GAO/AIMD-99-193  IRS Custodial
    Financial Management Weaknesses B-282731 provide refund activity
    by tax type for reporting in the footnotes to the financial
    statements as required by federal accounting standards.
    Consequently, IRS' custodial general ledger system cannot
    routinely generate reliable and timely financial information for
    either internal or external users. * Lacking an adequate general
    ledger system that complies with federal requirements, IRS must
    rely on various costly and time-consuming ad hoc procedures and
    adjustments.  These include cumbersome procedures for certifying
    revenue distributions to the various excise tax trust funds as
    well as extensive computer programming to extract needed
    information from its master files to support the preparation of
    its annual financial statements.  Addressing these problems
    through costly and time-consuming ad hoc procedures and
    adjustments, as IRS has had to do, is not a sound long-term
    solution. * The computer programming needed to extract information
    from IRS' master files requires an extensive technical knowledge
    of the master files which is possessed by very few individuals at
    IRS.  Should these individuals become unavailable for any reason,
    this approach could cease to be a viable option, and IRS would be
    forced to rely on a financial reporting process which, in the
    absence of such specialized expertise, cannot generate reliable
    custodial balances. In addition, during fiscal year 1998, IRS
    combined the financial reporting of its administrative and
    custodial activities, which had previously been reported and
    audited separately, into a single set of principal financial
    statements.27  However, IRS has not integrated these separate
    financial reporting processes under unified supervision at the
    operational level.  This lack of uniform supervision limits IRS'
    ability to provide integrated IRS financial reporting in the
    interim and unnecessarily complicates the annual financial
    reporting process.28 In the short term, IRS plans to continue to
    employ additional manual procedures until more modernized systems
    can be developed.  Therefore, it is critical that systems
    modernization be part of the long-term solution.  IRS plans to
    implement the first step of its systems modernization plan to
    begin to address some of the financial management deficiencies we
    have 27The Department of the Treasury Office of Inspector General
    audited IRS' fiscal year 1997 administrative activities. 28This
    issue and related recommendations will be addressed further in a
    separate report on IRS' administrative internal controls. Page 25
    GAO/AIMD-99-193  IRS Custodial Financial Management Weaknesses B-
    282731 identified.  While not solving all its problems,
    improvements planned may help reduce the dependence of IRS on a
    very limited resource of key employees who understand the master
    file structure. In addition, the remaining phases of the
    modernization plan are being reevaluated in light of changes in
    IRS' priorities caused by organizational and legislative changes.
    We will continue to monitor IRS' plans and progress toward systems
    modernization in our fiscal year 1999 audit.29 In the meantime,
    IRS will continue to depend upon ad hoc procedures for the
    development of its financial statements for years to come.
    Recommendation                  We recommend, that as a short-term
    action, IRS ensure that additional staff are employed and existing
    staff appropriately cross-trained to be able to perform the master
    file extractions and other ad hoc procedures needed for IRS to
    develop reliable balances for financial reporting purposes on a
    continuing basis. Agency Comments and  In commenting on this
    report, the Internal Revenue Service recognized the Our Evaluation
    magnitude of its financial management system deficiencies and
    internal control weaknesses, and outlined several initiatives
    planned or in progress that IRS believes will address a number of
    our short-term issues and recommendations.  IRS emphasized the
    long-term nature of its efforts to improve custodial financial
    management and the need to integrate these changes into its
    ongoing systems modernization plans.  In future audits, we will
    continue to monitor the effectiveness of IRS' initiatives in
    resolving the issues identified in this report. The complete text
    of IRS' response to this report is in appendix III. This report
    contains recommendations to you.  The head of a federal agency is
    required by 31 U.S.C. 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 within 60 days of the date of
    this letter.  A written statement also must be sent to the House
    and Senate Committees on 29A previous recommendation related to
    financial reporting is listed in appendix II, recommendation 1.
    Page 26                   GAO/AIMD-99-193  IRS Custodial Financial
    Management Weaknesses B-282731 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 Senator
    Ted Stevens, Senator Robert C. Byrd, Senator Orrin G. Hatch,
    Senator Max S. Baucus, Senator Fred Thompson, Senator Joseph
    Leiberman, Senator William V. Roth, Senator Daniel P. Moynihan,
    Representative Bill Archer, Representative Charles B. Rangel,
    Representative C.W. (Bill) Young, Representative David R. Obey,
    Representative Amo Houghton, Representative William J. Coyne,
    Representative Dan Burton, and Representative Henry A. Waxman, in
    their capacities as Chair or Ranking Minority Member of Senate and
    House Committees and Subcommittees.  We are also sending copies of
    this report to The  Honorable Lawrence Summers, Secretary of the
    Treasury, and The Honorable Jacob J. Lew, Director of the Office
    of Management and Budget. Copies will be made available to others
    on 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.  Other contacts
    and key contributors to this report are listed in appendix IV.
    Sincerely yours, Gregory D. Kutz Associate Director,
    Governmentwide Accounting And Financial Management Issues Page 27
    GAO/AIMD-99-193  IRS Custodial Financial Management Weaknesses
    Contents Letter
    1 Appendix I
    30 Scope and Methodology Appendix II
    32 Status of GAO Recommendations on IRS Custodial Activity
    Appendix III
    41 Comments From the Internal Revenue Service Appendix IV
    43 GAO Contacts and Staff Acknowledgements Related GAO Products
    47 Tables                    Table 1:  Internal Control and
    Compliance Issues Related to Unpaid Assessments 6 Table 2:
    Internal Control Issues Related to Manual Receipts and Taxpayer
    Data
    12 Table 3:  Internal Control Issues Related to Refunds and Earned
    Income Tax Credit Claims
    18 Table 4:  Internal Control and Compliance Issues Related to
    Revenue Reporting and Distribution
    21 Page 28             GAO/AIMD-99-193  IRS Custodial Financial
    Management Weaknesses Contents Table 5:  Internal Control and
    Compliance Issues Related to Financial Reporting 24 Table II.1:
    Fifteen Recommendations on IRS Custodial Financial Management That
    Remained Open                                               32
    Table II.2:  Twenty New Recommendations on IRS Custodial Financial
    Management 36 Table II.3:  Seven Recommendations on IRS Custodial
    Financial Management in This Report
    39 Figure    Figure 1:  Comparison of Unpaid Assessments Before
    and After Audit Adjustments as of September 30, 1998
    8 Abbreviations BPD         Bureau of the Public Debt EITC
    earned income tax credit FBI         Federal Bureau of
    Investigation FFMIA       Federal Financial Management Improvement
    Act FICA        Federal Insurance Contribution Act FMS
    Financial Management Service IRS Internal Revenue Service OMB
    Office of Management and Budget SSA         Social Security
    Administration TFRP        trust fund recovery penalty Page 29
    GAO/AIMD-99-193  IRS Custodial Financial Management Weaknesses
    Appendix I Scope and Methodology
    Appendix I As part of our audit of IRS' fiscal year 1998 financial
    statements, we evaluated IRS' internal controls, its compliance
    with selected provisions of laws and regulations, and followed up
    on the status of open recommendations.  Specifically, we: *
    performed multipurpose tests on selected statistical samples of
    unpaid assessment, revenue, and refund transactions and conducted
    analytical procedures; * performed detailed tests of transactions
    that represent the underlying basis of amounts distributed to the
    Highway, Airport and Airway, and Black Lung Disability trust
    funds; * reviewed daily, weekly, and monthly reconciliations,
    physical safeguards, and segregation of duties over cash and
    checks received and processed at service centers, district
    offices, post-of-duty offices and lockbox banks; * reviewed
    specific controls over refund processing and financial reporting;
* interviewed IRS managers at service centers, district offices,
    post-of-duty offices, and lockbox banks, and observed  processing
    procedures and controls; interviewed internal audit, internal
    security, and criminal investigation managers at selected service
    centers and district offices;1 * reviewed IRS' fiscal year 1998
    Federal Managers' Financial Integrity Act Annual Assurance
    Statement, Action Plan for GAO Recommendations dated January 8,
    1999, and two IRS letters to Congress dated January 29, 1999, and
    February 25, 1999, containing IRS' responses to recommendations in
    two recent GAO reports on IRS financial management;2 and, *
    reviewed IRS' quarterly certifications of excise tax revenue to
    the Highway, Airport and Airway, and Black Lung Disability trust
    funds. We also examined IRS' financial management systems to
    enable us to report on whether they substantially complied with
    Federal Financial Management Systems Requirements, applicable
    federal accounting standards, and the U.S. Government Standard
    General Ledger at the transaction level, as required by the
    Federal Financial Management 1The IRS Restructuring and Reform Act
    of 1998 replaced IRS' Office of Chief Inspector-which included
    internal audit and internal security-with the Office of the
    Treasury Inspector General for Tax Administration. 2GAO/AIMD-99-
    15, November 30, 1998 and GAO/AIMD-99-17, November 9, 1998. Page
    30                   GAO/AIMD-99-193  IRS Custodial Financial
    Management Weaknesses Appendix I Scope and Methodology Improvement
    Act of 1996 (FFMIA).  In addition, we considered the
    implementation guidance for FFMIA issued by OMB on September 9,
    1997, in Bulletin 98-08. Also, as part of our ongoing audit of
    IRS' fiscal year 1999 financial statements, we performed
    additional observations of processing procedures and controls at
    selected service centers, district offices, post-of-duty offices,
    and lockbox banks during the peak period of the 1999 tax filing
    season. Our work was performed at IRS' National Office in
    Washington D.C.; all 10 IRS service centers located across the
    country; 7 district offices; 7 post-of-duty offices; and 5 lockbox
    banks. Page 31                GAO/AIMD-99-193  IRS Custodial
    Financial Management Weaknesses Appendix II Status of GAO
    Recommendations on IRS Custodial Activity
    Appendix I I As of our prior report on the status of GAO
    recommendations on IRS custodial activity,1 15 recommendations
    related to IRS custodial financial management remained open.
    These are numbered 1 through 15 and are listed below with their
    current status.  Since the conclusion of our fiscal year 1997
    audit we have issued two additional reports2 related to IRS
    financial management which contained a total of 20 new
    recommendations.  These are numbered 16 through 35 in the chart
    below.3 Also, we are making seven new recommendations in this
    report as a result of our fiscal year 1998 audit and work
    performed as part of our ongoing fiscal year 1999 financial audit.
    These are numbered 36 through 42 below. We will continue to
    monitor IRS' progress toward addressing each of these
    recommendations during our fiscal year 1999 audit. Table II.1:
    Fifteen Recommendations on IRS Custodial Financial Management That
    Remained Open Status of GAO recommendations Recommendations
    reported by IRS in 1999a                       GAO status of
    recommendations Financial Management: Important IRS Revenue
    Information Is Unavailable or Unreliable (GAO/AIMD-94-22, December
    21, 1993) 1. Identify reporting information needs, develop
    Closed.  IRS reported that its contractor  Open.  As reported by
    IRS, the policies related sources of reliable information, and
    establish  had completed a draft set of policies           and
    procedures only cover IRS' and implement policies and procedures
    for compiling  and procedures in 1998 for preparing
    custodial financial statements and thus, this information.  These
    procedures should describe  the custodial financial statements.
    do not address any of the administrative any (1) adjustments that
    may be needed to available
    financial statements.  Because IRS now information and (2)
    analyses that must be performed
    prepares one set of financial to determine the ultimate
    disposition and
    statements, these policies and classification of amounts
    associated with in-process
    procedures do not cover all of its transactions and amounts
    pending investigation and
    financial reporting needs. resolution. 2.  Monitor implementation
    of actions to reduce the  Closed.  IRS reported that it would
    Open.  IRS currently expects to errors in calculating and
    reporting manual interest on  increase automation of the manual
    complete corrective actions in  2001. taxpayer accounts, and test
    the effectiveness of         interest calculations, develop a
    quality  We will follow up on IRS' these actions.
    review process, and measure accuracy. implementation as part of
    our fiscal year 1999 audit. (continued) 1See GAO/AIMD-99-16
    appendix II, October 30, 1998. 2GAO/AIMD-99-17, November 9, 1998,
    and GAO/AIMD-99-15, November 30, 1998. 3The current status of
    recommendations related to IRS' administrative activities will be
    addressed in a separate report on IRS' administrative internal
    controls. Page 32                   GAO/AIMD-99-193  IRS Custodial
    Financial Management Weaknesses Appendix II Status of GAO
    Recommendations on IRS Custodial Activity Status of GAO
    recommendations Recommendations
    reported by IRS in 1999a                 GAO status of
    recommendations Financial Audit: Examination of IRS' Fiscal Year
    1993 Financial Statements (GAO/AIMD-94-120, June 15, 1994) 3.
    Ensure that system development efforts provide  Closed.  IRS
    reported it is continuing        Closed.  Although IRS has not yet
    fully reliable, complete, timely, and comprehensive
    refinement of the Enforcement Revenue  addressed the identified
    problems, we information with which to evaluate the effectiveness
    Information System, which integrates        have since made
    several more specific of its enforcement and collection programs.
    data on enforcement recommendations,  recommendations to address
    IRS' assessments, collections, cost, and      ongoing need for
    more timely and case length on closed cases.             accurate
    information related to its efforts, see 5, 8, and 14 through19
    below. 4.  Establish and implement procedures to analyze
    Closed.  IRS reported it had             Closed.  Our fiscal year
    1998 audit the impact of abatements on the effectiveness of
    implemented program changes to more  identified several issues
    regarding assessments from IRS' various collections programs.
    accurately report on abatements.            abatements that, while
    needing attention by IRS management, do not constitute significant
    internal control deficiencies.  We are thus closing this
    recommendation but have separately issued a letter to IRS
    management discussing the issues identified in our fiscal year
    1998 audit and suggesting corrective actions to resolve them.
    Internal Revenue Service:  Immediate and Long-Term Actions Needed
    to Improve Financial Management (GAO/AIMD-99-16, October 30, 1998)
    5.  Manually review and eliminate duplicate or other  Closed.  IRS
    does not believe this is       Open.  We continue to believe this
    assessments that have already been paid off to
    achievable in the short-term and has     problem's significance
    warrants assure all accounts related to a single assessment
    convened a task force to develop              immediate action to
    prevent further are appropriately credited for payments received.
    programming specifications for           unnecessary taxpayer
    burden.  Waiting automating this process in the           for a
    long-term systems changewhich long-term.
    will likely take 10 years or more to implement-could continue to
    subject taxpayers to additional costs and hardships until the
    problem is fixed. 6.  Improve the accuracy of its master file
    extraction  Closed.  IRS made programming             Closed.
    Although IRS' FY 1998 unpaid programs used to classify unpaid
    assessments such  changes in FY 1998 that enabled it to
    assessment balances required that, once the extractions are made,
    any subsequent  extract data that was consistent with FY
    significant audit adjustments to correct adjustments needed would
    not be material.  At a          1997 final reported balances.
    misstated and duplicate unpaid minimum, IRS should consider the
    nature of the
    assessment balances identified by our adjustments made to the
    fiscal year 1997 amounts
    testing, further refinement of the master extracted and adjust the
    extraction programs in
    file extraction programs will not future years accordingly.
    significantly reduce these adjustments. (continued) Page 33
    GAO/AIMD-99-193  IRS Custodial Financial Management Weaknesses
    Appendix II Status of GAO Recommendations on IRS Custodial
    Activity Status of GAO recommendations Recommendations
    reported by IRS in 1999a                      GAO status of
    recommendations 7.  Establish minimum documentation standards or
    Open.  IRS reported it has established a  Open.  While we noted
    some checklists for collection files.  These standards or
    task force to develop a corrective action  improvements in our
    fiscal year 1998 checklists should include minimum documentation
    plan, which is expected to include            audit, such as in
    estate appraisal and file organization requirements for all taxes
    modifying procedures and training             documentation, IRS
    continued to receivable and compliance assessment cases,
    documents.  It expects to accomplish          experience
    difficulties in providing other specifying the types of
    documentation required,             this by January 2001.
    supporting documentation, such as that standard file organization,
    and the retention period
    for bankruptcy, non-estate installment that will ensure that such
    documents are maintained
    agreements, and older cases. until the statute of limitations has
    expired. 8.  Ensure that IRS' modernization blueprint includes
    Open.  IRS plans to develop a                      Open.  The
    success of the database to developing a subsidiary ledger to
    accurately and            subsidiary general ledger to identify,
    track and link multiple TFRP promptly identify, classify, track,
    and report all IRS      classify, track and report all unpaid
    assessments depends on service unpaid assessments by amount and
    taxpayer.  This  assessments except for trust fund
    center personnel manually inputting the subsidiary ledger must
    also have the capability to          recoveries.  However, the
    plan is             cross-reference information needed to
    distinguish unpaid assessments by category in order  expected to
    include the development of  link these assessments.  Therefore, to
    identify those assessments that represent taxes          a
    relational database that has the            even after the
    database is implemented, receivable versus compliance assessments
    and                capability to track and link multiple
    it will require significant manual effort to write-offs.  In cases
    involving trust fund recovery         TFRP assessments.
    ensure that it functions as needed.  In penalties, the subsidiary
    ledger should ensure that
    addition, the capability to ensure that (1) the trust fund
    recovery penalty assessment is
    TFRP payments are automatically appropriately tracked for all
    taxpayers liable but
    credited to individual accounts is not counted only once for
    reporting purposes and (2) all
    currently being developed. payments made are properly credited to
    the accounts of all individuals assessed for the liability. 9.
    Examine and consider options to increase                Open.  IRS
    is in the process of               Open. We will follow up on IRS'
    deterrent controls at service centers.  Some options  analyzing
    all potential deterrents to theft  implementation as part of our
    fiscal year IRS should examine and consider include:
    of cash, checks, and taxpayer data and  1999 audit. * installing
    surveillance cameras to monitor staff          expects to complete
    its analysis by June when they are opening, extracting and sorting
    the  30, 1999.  According to IRS officials, a mail, and when they
    are processing receipts,               plan based on the results
    of the analysis * restricting personal items that can be brought
    into  will be initiated by December 1999. the receipt processing
    areas, such as handbags, briefcases, and bulky outerwear, and *
    providing lockers and requiring their use for storing personal
    belongings outside of the receipt processing areas. 10.  Provide
    adequate training and monitoring of            Open.  IRS plans to
    develop a national  Open.  We will follow up on IRS' extraction
    unit staff to ensure staff are informed and  training course for
    mail extraction unit          implementation as part of our fiscal
    year properly trained on the proper procedures, and that  staff by
    August 1999.                                1999 audit. the
    procedures are being followed. 11.  Limit the units that may
    receive unopened mail  Closed.  IRS issued a policy to route
    Open.  We will follow up on IRS' directly to only those units
    which require                  mail through the service centers'
    receipt  implementation as part of our fiscal year confidentiality
    due to the nature of their work.  At a      and control function
    beginning January  1999 audit. minimum, mail addressed to off-site
    locations should  1, 1999, except for functions that require be
    routed through the service center first to identify
    confidentiality due to the nature of their mail that may contain
    taxpayer receipts.                    work. (continued) Page 34
    GAO/AIMD-99-193  IRS Custodial Financial Management Weaknesses
    Appendix II Status of GAO Recommendations on IRS Custodial
    Activity Status of GAO recommendations Recommendations
    reported by IRS in 1999a                    GAO status of
    recommendations 12.  Ensure that security guards and other
    Closed.  IRS issued a December 1998  Closed.  While IRS issued a
    policy unauthorized service center personnel do not
    memorandum (1) prohibiting guards           addressing this issue,
    we are making an receive walk-in payments from taxpayers.
    and other unauthorized personnel from  additional recommendation
    to reduce receiving payments and (2) specifying       the
    vulnerability of walk-in payments. procedures for deposit unit
    personnel to  See recommendation 40, below. receive such payments
    from taxpayers. 13.  Conduct a cost-benefit study to evaluate
    Open.  Although IRS agreed that             Open.  IRS has yet to
    conduct a whether preventive controls, such as manually
    reducing invalid refunds up front is        comprehensive study
    analyzing not only comparing W-2 and other third party information
    to  generally preferable, they believed that  the expected
    additional costs, but also tax returns at the time returns are
    received rather         manually comparing W-2s and other
    the benefits derived, such as the value than many months later,
    would be cost-beneficial.           third party documents during
    of invalid refunds that would be This study should include a
    complete analysis of the  processing is neither feasible nor
    prevented and cost savings from having projected costs and
    associated benefits of increases  practical.  IRS is requesting a
    fewer invalid refunds to pursue and to preventive controls.  If
    such controls are               programming change to identify
    attempt to collect. determined to be beneficial, IRS should
    implement           selected returns for reviewing W-2 data them
    to the extent practical to reduce the amount of  rather than doing
    so for all returns. inappropriate refund payments. 14.  Ensure
    that IRS' modernization blueprint               Open.  IRS
    contends that it plans to        Open.  This is a long-term
    solution for includes the ability to compare W-2 and other
    implement an automated matching of          which IRS does not
    have an estimated third-party information to tax returns as they
    are          W-2 and other third party information to  completion
    date. processed to further prevent improper refunds from  tax
    returns as they are processed. being issued.
    However, IRS reported that it would require changes in the tax
    code and tax document filing requirements. 15.  Implement Phase 0
    of IRS' systems                      Open.  IRS currently plans to
    implement  Open. We will monitor IRS' progress modernization plan
    as quickly as possible.  In doing  the first step of Phase 0 in
    2000.                during our fiscal year 1999 audit. so, IRS
    should incorporate plans to ensure that the resulting system can
    routinely generate timely and reliable financial management
    reports which can be used by internal and external users and which
    will increase the timeliness of preparation and audit of its
    annual financial statements.  Until Phase 0 is implemented, IRS
    should continue to utilize special computer programs and prepare
    manual adjustments, as needed, to derive amounts to be reported in
    the financial statements. aThe "Status of GAO Recommendations
    Reported by IRS in 1999" is based primarily upon the following IRS
    documents:  Action Plan for GAO Recommendations, January 8, 1999,
    and two letters to Congress dated January 29, 1999, and February
    25, 1999, laying out IRS' response to each of the recommendations
    in GAO/AIMD-99-15 and GAO/AIMD-99-17, respectively. Page 35
    GAO/AIMD-99-193  IRS Custodial Financial Management Weaknesses
    Appendix II Status of GAO Recommendations on IRS Custodial
    Activity Table II.2:  Twenty New Recommendations on IRS Custodial
    Financial Management Status of GAO recommendations Recommendations
    reported by IRS in 1999a                      GAO status of
    recommendations Excise Taxes: Internal Control Weaknesses Affect
    Accuracy of Distributions to the Trust Funds (GAO/AIMD-99-17,
    November 9, 1998) 16.  Determine if it would be cost-effective to
    develop  Closed. IRS reported that it                    Open.  We
    will follow up on IRS' and implement procedures requiring either
    key              implemented post-input controls to
    implementation during our fiscal year verification of the
    assessment amount by excise tax  review all returns with
    assessments of  1999 audit. type before final processing or to
    implement other         $1 million and over and all returns post-
    input controls to verify the accuracy of              reporting
    coal tax assessments of assessment amounts by tax type.  In making
    the             $100,000 or more.  Per IRS, these cover
    determination, IRS should consider establishing a          over 92
    percent of total excise tax dollar threshold that would ensure
    coverage of 90          assessments. percent of total excise tax
    assessments from the tax returns. 17.  Revise the Form 720 tax
    return to reflect a           Open.  IRS plans to explore the
    Open.  This is a mid- to long-term separate column adjacent to the
    column for entering  feasibility of adding a column on the
    solution.  As a result, errors associated the tax assessment, by
    abstract number, for the            Form 720 tax return or,
    alternatively, to  with adjustments affecting specific taxpayer to
    report on pages 1 and 2 of the tax return  increase the amount of
    data captured              excise tax amounts will continue to
    claims and adjustments, by abstract number, based  from the Form
    720 through its systems  occur in the short term. on the
    information the taxpayer reports on Schedule  modernization
    effort.  IRS plans to have C.
    systemic changes in place for the 2002 filing season. 18.
    Develop, document, and implement review               Closed.  IRS
    reported it developed new  Open. We will follow up on IRS'
    procedures over the adjustment and summarization  procedures and
    checksheets for excise  implementation during our fiscal year of
    assessment data used in the certifications.             tax trust
    fund certifications that require a  1999 audit . Specifically, IRS
    should require that detailed             separate checksheet for
    each trust fund. supervisory review be performed and documented to
    Additional staff have been assigned to ensure that adjustments are
    reasonable and                 analyze the data, and additional
    adequately supported, calculations are appropriately  supervisory
    reviews prior to certification performed, and the certification
    letter agrees with the  have been added. supporting schedules. 19.
    Establish and implement specific procedures           Closed.  IRS
    reported that a rate chart  Open.  We will follow up on IRS'
    requiring that IRS personnel review the distribution       has
    been developed and verified by the  implementation during our
    fiscal year rates provided by OTA prior to those rates being used
    legal counsels for each of the Form 720  1999 audit. in the
    certification of Highway Trust Fund                 trust fund
    agencies.  The table is to be distributions and document evidence
    of those               reviewed quarterly, used to update OTA
    reviews.                                                   models
    and monthly transfers, and maintained for audit trail purposes.
    (continued) Page 36                    GAO/AIMD-99-193  IRS
    Custodial Financial Management Weaknesses Appendix II Status of
    GAO Recommendations on IRS Custodial Activity Status of GAO
    recommendations Recommendations
    reported by IRS in 1999a                      GAO status of
    recommendations Internal Revenue Service: Physical Security Over
    Taxpayer Receipts and Data Needs Improvement (GAO/AIMD-99-15,
    November 30, 1998) 20.  Reevaluate the risk classification of all
    positions  Closed.  IRS decided on March 24,                Open.
    IRS did not provide an estimated in IRS' Receipt and Control
    Branch and reclassify            1999, that reevaluation of
    positions for  completion date for the other security. such
    positions where appropriate.
    reclassification was not needed and will  We will continue to
    monitor progress explore other security options.
    during fiscal year 1999. 21.  Establish procedures to review the
    applications  Open.  IRS plans to re-emphasize
    Open.  We will follow up on IRS' and associated documents for all
    applicants given            procedures and to procure live scan
    implementation during our fiscal year job offers to ensure that
    fingerprint checks are             fingerprint equipment
    compatible with         1999 audit. initiated on those
    individuals.  Implement procedures  FBI's Integrated Automated
    Fingerprint to provide supervisory feedback on these reviews as
    Identification System (IAFIS) to be necessary to ensure personnel
    staff are aware of             implemented about July 1999.  Once
    and follow IRS' policy requiring fingerprint checks.
    operational, fingerprint checks are expected to be completed in 5
    days. Also, IRS will review management reports and initiate
    actions to address fingerprinting deficiencies. 22.  Continue with
    the agency's plans to develop and  Open.  IRS issued a memorandum
    on                    Open.  We will follow up on IRS' implement a
    policy to fingerprint filing season              April 30, 1999,
    to all IRS support offices  implementation during our fiscal year
    applicants at the earliest possible time in the job          to
    fingerprint new employees upon             1999 audit. application
    process.                                         receipt of an
    application or upon passing written tests.  This is to be
    implemented no later than September 1, 1999. 23.  Until the
    problems with delays in fingerprint           Open.  IRS reported
    it would be unable  Open. We will follow up on IRS' checks are
    resolved, develop and implement a policy  to comply during the
    1999 filing season.   implementation during our fiscal year
    prohibiting new employees from being assigned to
    However, it expects that implementation  1999 audit. process
    receipts until the results of fingerprint            of FBI's
    IAFIS system in July 1999 checks are received and reviewed by
    management.   should resolve this problem for future filing
    seasons. 24.  Continue the agency's efforts to explore the
    Open.  IRS reported it plans to expand  Open.  We will follow up
    on IRS' feasibility of obtaining local police checks on IRS
    the local police check capability to other  implementation during
    our fiscal year applicants and evaluate the efficiency and
    facilities and is testing a pilot program to  1999 audit.
    effectiveness of the Philadelphia Service Center's
    establish procedures with local police to electronic
    fingerprinting system  in order to                provide this
    service. supplement FBI fingerprint checks. 25.  Continue the
    agency's efforts to negotiate with  Open.  IRS reported it has
    procured the  Open.  We will follow up on IRS' OPM and the FBI and
    procure the necessary                    equipment and delivered
    it to 17 IRS          implementation during our fiscal year
    equipment so that it can participate in FBI's IAFIS          sites
    including the 10 service centers.  It  1999 audit. program by
    August 1999.                                      has requested to
    be a pilot for IAFIS when it comes on-line in summer 1999. 26.
    Improve the physical security over receipts and  Open.  IRS is
    assessing the space issue  Open.  We will continue to monitor
    returns stored in unsecured overflow areas.  These  at its service
    centers to determine                    progress during our fiscal
    year 1999 controls might include limiting unnecessary traffic by
    where the overflow mail can be properly  audit. temporarily
    designating these overflow areas as              stored and
    secured.  IRS expects to restricted access areas and/or posting
    additional            have improved security over overflow
    security guards over such areas during the peak              mail
    by April 2000. filing season. (continued) Letter
    Page 37                    GAO/AIMD-99-193  IRS Custodial
    Financial Management Weaknesses Appendix II Status of GAO
    Recommendations on IRS Custodial Activity Status of GAO
    recommendations Recommendations
    reported by IRS in 1999a                     GAO status of
    recommendations 27.  Ensure that all final candling activities are
    Open.  IRS is working with the service  Open.  We will continue to
    monitor consistently located in a restricted access area.
    centers to assess the space issue and  progress during our fiscal
    year 1999 expects to have all final candling           audit.
    activities located in restricted access areas by January 2000. 28.
    Provide secure containers for service center             Closed.
    In February 1999, IRS issued a  Open.  We will follow up on IRS'
    employees to store "discovered remittances" prior to  memorandum
    that re-emphasizes                        implementation during
    our fiscal year inventory and submission to the Receipt and
    Control  instructions for handling these
    1999 audit. Branch.  Immediately upon discovery, the receipts
    remittances, including storing should be recorded into a control
    log, the receipts           discovered remittances in a secure
    secured in a locked container, and the discovered
    container and recording the information receipts reconciled to the
    control log prior to               on Form 4287, Record of
    Discovered submission for processing.
    Remittance. 29.  Ensure that all unmatched checks are stored in
    Open.  IRS is in the process of obtaining  Open.  We will follow
    up on IRS' locked containers until they can be researched and
    suitable containers for storing
    implementation during our fiscal year processed for deposit.
    unmatched checks in service centers by  1999 audit. August 1999.
    30.  Ensure that all returned refund checks are
    Closed.  IRS issued a supplemental           Open.  We will follow
    up on IRS' stamped "non-negotiable" as soon as they are
    procedure to reinforce overstamping of  implementation during our
    fiscal year extracted.
    returned refund checks as soon as they  1999 audit. are extracted.
    31.  Require district office employees to store walk-in  Closed.
    In November 1998, IRS issued  Open. We will follow up on IRS'
    payments in secure containers in accordance with              new
    guidelines for safeguarding receipts  implementation during our
    fiscal year IRM 1(16) 41, section 500.  District office
    of cash and noncash payments received  1999 audit. management
    should ensure that this policy is                  in walk-in
    facilities. followed and should limit the number of employees with
    access to the keys or combinations to these containers. 32.
    Ensure that walk-in payment receipts are                 Closed.
    IRS issued new guidelines for  Open.  We will follow up on IRS'
    recorded in a control log prior to depositing the
    recording and reconciling receipts.          implementation during
    our fiscal year receipts in the locked container and ensure that
    the                                                       1999
    audit. control log information is reconciled to receipts prior to
    submission of the receipts to another unit for payment processing.
    To ensure proper segregation of duties, an employee not
    responsible for logging receipts in the control log should perform
    the reconciliation. 33.  Study the feasibility of improving
    security for          Open. IRS issued a directive in April
    Open. We will continue to monitor deposits in transit.  In
    conducting this study, IRS           1999 that required couriers
    to be            progress during our fiscal year 1999 should
    consider a number of alternatives including            bonded and
    use locked, enclosed              audit. the use of depositories
    in close proximity to its             vehicles.  IRS reported it
    is also various field locations and employing security guards
    upgrading service center requirements to accompany couriers to the
    depositories.                    to include the use of armed
    couriers, and plans to have all field offices send tax receipts by
    overnight mail to designated service centers by August 1999. It
    has also initiated a study to investigate other alternatives for
    transporting deposits. (continued) Page 38
    GAO/AIMD-99-193  IRS Custodial Financial Management Weaknesses
    Appendix II Status of GAO Recommendations on IRS Custodial
    Activity Status of GAO recommendations Recommendations
    reported by IRS in 1999a                    GAO status of
    recommendations 34.  Develop a policy to ensure that contracts
    related  Open.  Once the study on transporting  Open.  We will
    continue to monitor to courier services do not unduly expose the
    deposits is completed, IRS plans to         progress during our
    fiscal year 1999 government to losses in the event of lost,
    stolen, or      develop a policy.   Implementation of the  audit.
    damaged deposits in transit.
    contractor's findings is scheduled for August 1999. 35.  Ensure
    that courier access is limited to service  Open.  IRS reported it
    is working to            Open.  No time frames have been center
    premises.  Deposit Unit employees should            determine the
    best solution to this issue.   established for what corrective
    action deliver the deposits to couriers waiting at the guard
    will be taken and when this effort might station instead of
    providing courier badges allowing
    be completed. them unnecessary service center access. aThe "Status
    of GAO Recommendations Reported by IRS in 1999" is based primarily
    upon the following IRS documents:  Action Plan for GAO
    Recommendations, January 8, 1999, and two letters to Congress
    dated January 29, 1999, and February 25, 1999, laying out IRS'
    response to each of the recommendations in GAO/AIMD-99-15 and
    GAO/AIMD-99-17, respectively. Table II.3:  Seven Recommendations
    on IRS Custodial Financial Management in This Report Status of GAO
    recommendations Recommendations
    reported by IRS in 1999a                   GAO status of
    recommendations Internal Revenue Service:  Custodial Financial
    Management Weaknesses (GAO/AIMD-99-193, August 4, 1999) 36.
    Analyze and determine the factors causing delays  Not
    applicablenew recommendation.                New recommendation.
    in processing and posting trust fund recovery penalty assessments.
    Once these factors have been determined, IRS should develop
    procedures to reduce the impact of these factors and to ensure
    timely posting to all applicable accounts and proper offsetting of
    refunds against unpaid TFRP assessments before issuance. 37.
    Identify and institute procedures to monitor            Not
    applicablenew recommendation.         New recommendation.
    compliance of installment agreements.  Such monitoring should
    ensure that the installment agreements provide for full payment of
    the taxes owed.  For example, management could randomly select
    installment agreements from all of its units to review for
    compliance with the Internal Revenue Code. (continued) Page 39
    GAO/AIMD-99-193  IRS Custodial Financial Management Weaknesses
    Appendix II Status of GAO Recommendations on IRS Custodial
    Activity Status of GAO recommendations Recommendations
    reported by IRS in 1999a                   GAO status of
    recommendations 38. Expand IRS' current review of service center
    Not applicablenew recommendation.         New recommendation.
    deterrent controls to include similar reviews of controls at IRS
    district offices and post-of-duty offices in areas such as courier
    security, safeguarding of receipts in locked containers,
    requirements for fingerprinting employees, and requirements for
    promptly over-stamping checks made out to "IRS" with "Internal
    Revenue Service" or "United States Treasury". Based on the
    results, IRS should make appropriate changes to strengthen its
    controls at these locations. 39. IRS should work with Treasury's
    Financial                   Not applicablenew recommendation.
    New recommendation. Management Service (FMS) to revise the current
    lockbox contracts to specifically require that: * background
    checks be completed before employees begin working, * temporary
    employees be subjected to background checks that are consistent
    with those required of IRS employees, and * taxpayer data and
    receipts in transit to and from the lockbox banks are
    appropriately protected. 40.  Require service center staff to
    provide receipts to  Not applicablenew recommendation.
    New recommendation. all walk-in taxpayers regardless of the method
    of payment.  In addition, IRS should post signs reminding
    taxpayers to request receipts.  At service centers not normally
    equipped to receive walk-in payments, all receipts should be
    logged in to ensure completeness and accuracy of receipts and
    deposits. 41.  Establish procedures to ensure the prompt
    Not applicablenew recommendation.         Not applicablenew
    recommendation. recording of tax returns.  IRS should implement
    controls to ensure that excise tax returns are recorded timely and
    included in the quarterly excise tax trust fund certifications.
    42. Ensure that additional staff are employed and
    Not applicablenew recommendation.         New recommendation.
    existing staff appropriately cross-trained to be able to perform
    the master file extractions and other ad hoc procedures needed for
    IRS to develop reliable balances for financial reporting purposes
    on a continuing basis. aThe "Status of GAO Recommendations
    Reported by IRS in 1999" is based primarily upon the following IRS
    documents:  Action Plan for GAO Recommendations, January 8, 1999,
    and two letters to Congress dated January 29, 1999, and February
    25, 1999, laying out IRS' response to each of the recommendations
    in GAO/AIMD-99-15 and GAO/AIMD-99-17, respectively. Page 40
    GAO/AIMD-99-193  IRS Custodial Financial Management Weaknesses
    Appendix III Comments From the Internal Revenue ServiceAppendix
    III Page 41    GAO/AIMD-99-193  IRS Custodial Financial Management
    Weaknesses Appendix III Comments From the Internal Revenue Service
    Page 42              GAO/AIMD-99-193  IRS Custodial Financial
    Management Weaknesses Appendix IV GAO Contacts and Staff
    Acknowledgements Appendix IV GAO Contacts        Steven J.
    Sebastian  (202) 512-3406 Doreen Eng  (206) 287-4858
    Acknowledgements    In addition to those named above, the
    following individuals made key contributions to this report:
    Julianne Hartman Cutts, Catherine W. Arnold, Stan Stenerson, and
    Charles R. Fox. Page 43            GAO/AIMD-99-193  IRS Custodial
    Financial Management Weaknesses Page 44    GAO/AIMD-99-193  IRS
    Custodial Financial Management Weaknesses Page 45    GAO/AIMD-99-
    193  IRS Custodial Financial Management Weaknesses Page 46
    GAO/AIMD-99-193  IRS Custodial Financial Management Weaknesses
    Related GAO Products Internal Revenue Service:  Results of Fiscal
    Year 1998 Financial Statement Audit (GAO/T-AIMD-99-103, March 1,
    1999). Financial Audit:  IRS' Fiscal Year 1998 Financial
    Statements (GAO/AIMD-99-75, March 1, 1999). IRS Systems Security:
    Although Significant Improvements Made, Tax Processing Operations
    and Data Still at Serious Risk (GAO/AIMD-99-38, December 14,
    1998). Internal Revenue Service:  Physical Security Over Taxpayer
    Receipts and Data Needs Improvement (GAO/AIMD-99-15, November 30,
    1998). Excise Taxes:  Internal Control Weaknesses Affect Accuracy
    of Distributions to the Trust Funds (GAO/AIMD-99-17, November 9,
    1998). Internal Revenue Service:  Immediate and Long-Term Actions
    Needed to Improve Financial Management (GAO/AIMD-99-16, October
    30, 1998). Internal Revenue Service:  Composition and
    Collectibility of Unpaid Assessments (GAO/AIMD-99-12, October 29,
    1998). Internal Revenue Service:  Remaining Challenges to Achieve
    Lasting Financial Management Improvements (GAO/T-AIMD/GGD-98-139,
    April 15, 1998). Financial Audit:  Examination of IRS' Fiscal Year
    1997 Custodial Financial Statements (GAO/AIMD-98-77, February 26,
    1998). Tax Systems Modernization: Blueprint Is a Good Start But
    Not Yet Sufficiently Complete to Build or Acquire Systems
    (GAO/AIMD/GGD-98-54, February 24, 1998). Financial Audit:
    Examination of IRS' Fiscal Year 1996 Custodial Financial
    Statements (GAO/AIMD-98-18, December 24, 1997). Financial Audit:
    Examination of IRS' Fiscal Year 1995 Financial Statements
    (GAO/AIMD-96-101, July 11, 1996). Financial Audit:  Examination of
    IRS' Fiscal Year 1994 Financial Statements (GAO/AIMD-95-141,
    August 4, 1995). Letter    Page 47            GAO/AIMD-99-193  IRS
    Custodial Financial Management Weaknesses Related GAO Products
    Financial Audit:  Examination of IRS' Fiscal Year 1993 Financial
    Statements (GAO/AIMD-94-120, June 15, 1994). Financial Management:
    Important IRS Revenue Information is Unavailable or Unreliable
    (GAO/AIMD-94-22, December 21, 1993). Financial Audit:  Examination
    of IRS' Fiscal Year 1992 Financial Statements (GAO/AFMD-93-2, June
    30, 1993). Financial Audit:  IRS Significantly Overstated its
    Accounts Receivable Balance (GAO/AFMD-93-42, May 6, 1993). Federal
    Tax Deposit System:  IRS Can Improve the Federal Tax Deposit
    System  (GAO/AFMD-93-40, April 28, 1993). (919354)    Letter
    Page 48                 GAO/AIMD-99-193  IRS Custodial Financial
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