BNUMBER: B-259947
DATE: November 28, 1995
TITLE: Federal Executive Board--Appropriations--Employee Tax
Returns--Electronic Filing
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Matter of:Federal Executive Board--Appropriations--Employee Tax
Returns--Electronic Filing
File: B-259947
Date: November 28, 1995
DIGEST
In the absence of statutory authority, member agencies of the New
Orleans Federal Executive Board may not use appropriations to provide
employees with the means to electronically file their personal income
tax returns because such costs are personal to the employees.
Exceptions to this rule have been permitted where the expenditure
primarily benefits the agency. Absent specific statutory authority,
in order to use appropriated funds for this purpose, each agency must
demonstrate that the employee electronic filing program is reasonably
related to the purpose of the agency's appropriation.
DECISION
The Chair of the New Orleans Federal Executive Board has requested our
opinion regarding whether federal agencies in New Orleans, other than
the Internal Revenue Service (IRS), may use their appropriations to
provide computer hardware and pay related expenses to enable employees
to electronically file their personal income tax returns. For the
reasons discussed below, we conclude that before a federal agency may
pay for an employee electronic filing program, it must show that the
program is necessary or incidental to the purpose of its
appropriation.
Background
The New Orleans Federal Executive Board is a quasi-governmental
organization composed of the chief federal executives in the New
Orleans area. The Board coordinates governmental policy on matters
impacting the New Orleans federal community and provides leadership in
the sharing of services between agencies.
The Board has asked us whether its member agencies may provide their
employees with the means to electronically file their personal income
tax returns from agency offices at no cost to the employees. This
question arose after the Director of the New Orleans District of the
IRS informed the Board that our Office had authorized IRS to implement
an agency-wide employee electronic tax return program. See 71
Comp. Gen. 28 (1991). The Director stated that this program should be
extended to other federal agencies and that IRS would furnish entry
and communication software to any agency willing to provide the
computer hardware and telephone lines necessary to electronically
transmit the employee personal income tax returns to IRS.
Discussion
As a general matter, agency appropriations are not available to pay
the costs of filing employee income tax returns. Because the Internal
Revenue Code imposes the duty on taxpayers to file returns, 26 U.S.C.
6011, 6012, the cost of electronically filing a tax return is
considered a personal expense of the employee. Unless the agency can
show that the expense primarily benefits the government, personal
expenses of employees are not payable from appropriated funds absent
specific statutory authority. 68 Comp. Gen. 502, 505 (1989).
In our decision approving the use of appropriations to implement the
IRS employee electronic tax return program, we held that IRS overcame
the personal expense prohibition because it clearly and convincingly
explained the link between the expenditure and the benefit to the IRS.
71 Comp. Gen. at 30. See 68 Comp. Gen. at 505. IRS explained
that the employee electronic filing program would be used to publicize
the benefits of electronic filing, familiarize IRS employees with the
Electronic Filing System and permit IRS to evaluate and refine the
system. 71 Comp. Gen. at 29. Based on this, we agreed with
IRS that the employee electronic filing program was reasonably related
to the purpose of the agency's "processing tax returns" appropriation.
Although IRS employees received some benefit from the program, we
concluded that the personal benefit to employees was nominal and
collateral to overall IRS system improvement. In accordance with the
prior decision, we would not object to IRS's use of its "processing
tax returns" appropriation to pay all reasonable costs of electronic
filing at other federal agencies.
If other agencies want to use their appropriations for this purpose,
they must establish, as did IRS, that the expenditure will directly
support agency responsibilities. 68 Comp. Gen. at 505. See B-214833,
Aug. 22, 1984. The other federal agencies in New Orleans would have
to show that the use of federal funds to pay for employees' electronic
filing of tax returns is necessary or incidental to the objects of the
appropriations to be charged. Accordingly, in the absence of an
agency's justification of the availability of its own appropriation
for this purpose, similar to that provided by IRS, we cannot approve
of an agency's use of its appropriations to finance employees'
electronic filing of tax returns.
/s/Robert P. Murphy
for Comptroller General
of the United States