Management Letter: Improvements Needed in IRS' Accounting	 
Procedures and Internal Controls (30-JUL-01, GAO-01-880R).	 
								 
In March 2001, GAO issued a report on (GAO-01-394) the results of
its audit of the Internal Revenue Service's (IRS) financial	 
statements and on the effectiveness of its internal controls as  
of, and for the fiscal year ending, September 30, 2000. GAO also 
reported its conclusions on IRS' compliance with significant	 
provisions of selected laws and regulations and on whether IRS'  
systems substantially comply with requirements of the Federal	 
Financial Management Improvement Act of 1996. This report reviews
additional matters identified during GAO's fiscal year 2000 audit
regarding accounting procedures and internal controls that could 
be improved. GAO found that IRS had immaterial internal control  
issues that affected reporting. IRS (1) was unable to determine  
if its costs for reimbursable activities were accurate and	 
whether it was recouping the costs of the goods or services it	 
provided, (2) did not have procedures in place to properly record
its working capital fund prepaid expenses, (3) accepted 	 
information from its contractors for inclusion in its year-end	 
financial reporting without sufficient oversight or review, and  
(4) did not always follow standard procedures with respect to the
transfer of funds between appropriations.			 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-01-880R					        
    ACCNO:   A01483						        
  TITLE:     Management Letter: Improvements Needed in IRS' Accounting
             Procedures and Internal Controls                                 
     DATE:   07/30/2001 
  SUBJECT:   Accounting procedures				 
	     Accounting standards				 
	     Financial management systems			 
	     Financial records					 
	     Financial statement audits 			 
	     Internal controls					 
	     Reporting requirements				 
	     Treasury On-Line Payment and Collection		 
	     System						 
								 
	     Treasury Working Capital Fund			 

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GAO-01-880R
     
GAO- 01- 880R IRS Management Letter

United States General Accounting Office Washington, DC 20548

July 30, 2001 The Honorable Charles O. Rossotti Commissioner of Internal
Revenue

Subject: Management Letter: Improvements Needed in IRS? Accounting
Procedures and Internal Controls

Dear Mr. Rossotti: In March 2001, we issued our report on the results of our
audit of the Internal Revenue Service?s (IRS) financial statements and on
the effectiveness of its internal controls as of, and for the fiscal year
ending, September 30, 2000. 1 We also reported our conclusions on IRS?
compliance with significant provisions of selected laws and regulations and
on whether IRS? systems substantially comply with requirements of the
Federal Financial Management Improvement Act of 1996. We are in the process
of preparing a separate report addressing the significant internal control
and compliance issues identified and highlighted in our March 2001 audit
report.

The purpose of this letter is to report additional matters identified during
our fiscal year 2000 audit regarding accounting procedures and internal
controls that could be improved. These matters are not considered material
in relation to the financial statements; however, they warrant management?s
consideration.

Results in Brief

During fiscal year 2000, IRS had several immaterial internal control issues
that affected financial reporting. These issues concern policies and
procedures over (1) reimbursable activity, (2) property and equipment (P& E)
purchased through the Department of the Treasury?s working capital fund
(WCF), 2 (3) oversight of financial reporting- related contractor support,
and (4) transfers of funds between appropriations.

Specifically, we found the following. 1 Financial Audit: IRS? Fiscal Year
2000 Financial Statements (GAO- 01- 394, Mar. 1, 2001). 2 The WCF is a
revolving fund established to provide centralized administrative services to
be used by more than one bureau or agency. Although the bureaus and agencies
provide the funds that finance it, the WCF owns the property and equipment
purchased.

GAO- 01- 880R IRS Management Letter Page 2

 IRS was unable to determine if its costs for reimbursable activities were
accurate and whether it was recouping the costs of the goods or services it
provided. Also, IRS? records regarding reimbursable amounts not yet paid
(reimbursable receivables) were not reliable.

 IRS did not have procedures in place to properly record its WCF prepaid
expenses. The lack of such procedures resulted in IRS understating its
assets and overstating its expenses by $7.3 million in fiscal year 2000.

 IRS accepted information from its contractors for inclusion in its year-
end financial reporting without sufficient oversight or review. This allowed
uncorrected data related to P& E and undelivered orders to be included in
the generation of IRS? financial statements that, without audit adjustments,
could have led to erroneous information being reported by IRS.

 IRS did not always follow standard procedures with respect to the transfer
of funds between appropriations. Specifically, IRS recorded a transfer of
budgetary authority in its general ledger 7 months before Treasury processed
the transfer.

At the end of our discussion on each of these issues, we offer
recommendations for strengthening IRS? internal controls.

In responding to a draft of this letter, IRS agreed with portions of the
letter, but disagreed with the issues regarding prepaid expenses and lack of
contractor oversight. At the end of our discussion of each of the issues in
this letter, we have summarized IRS? related comments and provided our
evaluation. The complete text of IRS? response is included in enclosure I to
this letter.

Scope and Methodology

As part of our audit of IRS? fiscal year 2000 financial statements, we
evaluated IRS? internal controls and its compliance with selected provisions
of laws and regulations. We designed our audit procedures to test relevant
controls and included tests for proper authorization, execution, accounting,
and reporting of transactions.

We conducted our fiscal year 2000 audit in accordance with U. S. generally
accepted government auditing standards. Further details on our scope and
methodology are included in our March 2001 report on the results of our
fiscal year 2000 financial statement audit. 3

3 GAO- 01- 394, Mar. 1, 2001.

GAO- 01- 880R IRS Management Letter Page 3

IRS Needs Procedures to Properly Track and Report Reimbursable Activity

During our fiscal year 2000 financial audit, we noted a number of issues
related to IRS? tracking and reporting of reimbursable activity. 4 These
issues resulted in both IRS? inability to provide accurate cost information
and in misstatements in accounts used to record and report reimbursable
activity. We reported on inaccuracies in reimbursable activity records last
year. 5

U. S. generally accepted accounting principles (GAAP) recognize that
reliable information on costs of federal programs and activities is crucial
for effective management of government operations and is especially
important to assess operating performance. 6 Specifically, the accounting
standards require that when an entity provides goods or services to another
entity, regardless of whether full reimbursement is received, the providing
entity should recognize in its accounting records the full cost of those
goods or services. The full costs of the goods or services should also be
reported to the receiving entity by the providing entity. Regarding the need
to maintain accurate records, GAO?s Standards for Internal Control in the
Federal Government 7 states that internal control should generally be
designed to assure that ongoing monitoring occurs in the course of normal
operations. This includes regular management and supervisory activities,
comparisons, reconciliations, and other actions people take in performing
their duties.

IRS? accounting systems did not track or report cost information at the
level necessary to determine the actual cost of reimbursable activities as
required by federal accounting standards. For reimbursable activity, IRS
bills customers using estimates of costs for the goods or services it
provides. Although the use of estimates is a valid accounting practice, IRS?
systems did not adequately capture the actual cost of these goods and
services they provide. Because of this, IRS was unable to determine if its
estimates were accurate and whether it was recouping the costs of the goods
or services it provided. Additionally, this prevented IRS from reporting
reliable cost information to program managers, the Congress, and other
interested parties.

4 IRS provides goods and services to federal agencies, state and foreign
governments, and private organizations on a reimbursable cost basis.
Payments due to IRS for these activities are referred to as reimbursable
receivables.

5 Management Letter: Suggested Improvements in IRS? Accounting Procedures
and Internal Controls (GAO/ AIMD- 00- 162R, June 14, 2000). 6 Statement of
Federal Financial Accounting Standards (SFFAS) No. 4 (para. 108).

7 Standards for Internal Control in the Federal Government (GAO/ AIMD- 00-
21.3.1, Nov. 1999), contains the internal control standards to be followed
by executive agencies in establishing and maintaining systems of internal
control as required by 31 U. S. C. sec. 3512 (commonly referred to as the
Federal Managers? Financial Integrity Act).

GAO- 01- 880R IRS Management Letter Page 4 We also found that the records
IRS maintains regarding reimbursable amounts not

yet paid (reimbursable receivables) were not reliable. IRS did not routinely
age or analyze its receivables to ensure their validity. We tested a
nonrepresentative selection of six reimbursable receivables at the end of
fiscal year 2000 and found errors in the records for five of the accounts.
Specifically, we found that three of the receivables (50 percent) in our
nonrepresentative selection had already been paid and were therefore no
longer valid receivables. The other two receivables had been outstanding for
several years and had previously been identified by IRS as uncollectible.
Although they should have been written off in the detailed records, these
items were still recorded as valid receivables. This is consistent with our
findings reported in last year?s management letter, in which we noted that
54 percent of the reimbursable receivables we tested were no longer valid.

Because IRS did not routinely review its reimbursable receivables, it was
unable to identify invalid or inaccurate receivables and make the needed
corrections. Proper analysis through aging and reconciliation of IRS?
records is a part of good management practice and could have identified
these inaccuracies and allowed IRS to correct its records of reimbursable
receivables. Additionally, providing accurate general and subsidiary ledger
balances reflecting only valid receivables would better support management
in its collection efforts and provide for more reliable and easily
verifiable reporting to management.

Recommendations To allow the proper reporting of the cost of reimbursable
activity, we recommend that you ensure that IRS personnel

 develop a mechanism to track and report the actual costs associated with
reimbursable activities.

To provide for more accurate records and better management of reimbursable
activity, we recommend that you ensure that IRS personnel

 establish procedures to periodically reconcile the subsidiary records to
the control account for reimbursable receivables to ensure that the balance
is adequately supported and

 routinely age and review currently open reimbursable receivable accounts
to identify accounts that are no longer valid or collectible.

IRS? Comments and Our Evaluation In its comments, IRS noted that, with few
exceptions, it does not bill its customers in advance of providing goods or
services. We agree, and have modified the language accordingly. IRS did not
address our recommendations that it track the actual costs of reimbursable
activity or that it establish procedures to reconcile its records of
reimbursable receivables and routinely review the status of those
receivables.

GAO- 01- 880R IRS Management Letter Page 5

IRS Needs Procedures to Properly Account for Prepaid Expenses and Treasury
Working Capital Fund Assets

During our fiscal year 2000 audit, we continued to find issues with respect
to IRS? accounting procedures for certain assets paid for in one year but
used for several years. GAAP 8 define such payments as prepayments and
require agencies to record them as assets (prepaid expenses) in the year of
payment because the cost of the goods and services will benefit the entity
in future years. Recording an asset in this way and expensing the cost
systematically over the asset?s useful life is necessary in order to match
the expense with the period in which the benefit is received. Doing so gives
management reliable information on the cost of federal programs- an
important part of assessing operating performance.

However, IRS recorded the entire cost as an expense at the time of purchase.
IRS purchases a significant portion of its telecommunications services
through Treasury?s WCF. The WCF purchases and retains ownership of capital
items (such as telephone routers) for IRS and bills IRS for the full cost of
these items in the year of purchase. Although the equipment is located at
IRS offices and IRS benefits from the purchase for a number of years, IRS
has been recognizing the full cost of these items as an expense in the first
year.

When we identified this issue in the previous year?s audit, IRS corrected
the problem for fiscal year- end financial reporting. To do so, IRS used a
contractor to estimate its prepaid expenses by statistically projecting the
net book value of WCF assets at IRS locations in order to properly reflect
prepaid expenses on its balance sheet as of September 30, 1999. The
contractor physically inventoried a sample of WCF assets at IRS locations
and then projected the value of the assets. As a result of this projection,
IRS made a $21.7 million adjustment to reflect this amount as a prepaid
expense on its September 30, 1999, balance sheet. Although we suggested in
last year?s management letter that IRS develop procedures to record
prepayments as assets in future periods, IRS still did not have such
procedures in place to properly record its WCF prepaid expenses for fiscal
year 2000. The lack of such procedures resulted in IRS understating its
assets and overstating its expenses by $7.3 million in fiscal year 2000.

In last year?s audit, we identified two additional issues related to the
WCF. In a separate management letter, 9 we made several suggestions to help
IRS strengthen its procedures and controls in this area. We found during
this year?s audit that IRS had implemented corrective action based on one of
these suggestions. Specifically, IRS

8 SFFAS No. 1, Accounting for Selected Assets and Liabilities, provides
accounting standards for selected assets and liabilities. Paragraph 58 of
SFFAS No. 1 defines prepayments (prepaid expenses) and paragraph 59 states
prepayments should be recorded as assets. Statement of Accounting Standards
No. 4, Managerial Cost Accounting Standards, (paras. 5 to 11) provides
concepts and standards aimed at providing reliable and timely information on
the full cost of federal programs and their activities and outputs.

9 GAO/ AIMD- 00- 162R, June 14, 2000.

GAO- 01- 880R IRS Management Letter Page 6 agreed with our suggestion to
remove multiple property tags from property at IRS

locations. 10 During this year?s audit we did not identify any instances of
property with multiple tags. We also found during this year?s audit that IRS
has removed WCF items from its records, thus addressing the underlying issue
that gave rise to our suggestion.

Recommendation We recommend that IRS develop and implement procedures to
require that prepayments be recorded as assets routinely at the time the
cost is incurred in accordance with GAAP. Services that are provided to IRS
that will benefit IRS for more than 1 year should be established as prepaid
expenses and amortized over the period of the benefit.

IRS? Comments and Our Evaluation In commenting on this section, IRS stated
that it records Online Payment and Collection billings from the WCF as a
prepaid asset and then decides how much of the asset to charge to expense
based on reports it receives from the WCF. However, most of the equipment
purchased by the WCF, which is used by IRS, is expensed by the WCF in the
year of purchase due to its capitalization threshold. Therefore, by using
the WCF reports as a basis for determining how much of the cost should be
expensed, IRS effectively expenses this equipment in the year of purchase
even though it will benefit IRS for more than 1 year. The accounting
treatment of these items by the WCF should not affect how IRS accounts for
the amounts paid for the use of the equipment. Because procedures were not
in place to properly account for these costs, IRS understated its assets and
overstated its expenses by $7.3 million in fiscal year 2000.

IRS Needs Better Oversight of Financial Reporting- Related Contractor
Support

In previous years, and again this year, we noted a number of errors and
discrepancies in IRS financial records that could have been avoided or
corrected by greater management oversight and review. During fiscal year
1999, we reported that IRS did not perform sufficient supervisory review to
detect and eliminate errors and thus ensure that transactions were properly
recorded and adequately supported and that reports were properly prepared.
11 We suggested that IRS revise its policies and procedures to require
documented and sufficiently detailed supervisory reviews of transactions to
ensure that transactions are correct and adequately supported and

10 The suggestion arose because we found that many of the telecommunication
equipment items we observed at IRS facilities had both IRS and WCF tags.
Having multiple tags made it difficult to determine whether these items
should have been recorded in IRS or Treasury WCF records.

11 GAO/ AIMD- 00- 162R, June 14, 2000.

GAO- 01- 880R IRS Management Letter Page 7 that reports are properly
prepared before information is summarized and reported

externally. During fiscal year 2000, IRS contracted out several activities
that directly supported its year- end financial reporting process. However,
it did not maintain sufficient oversight of these contractors to ensure that
their work was reliable. This hampered IRS? ability to ensure reasonable
controls existed over the accuracy of its reported financial information.

GAO?s Standards for Internal Control in the Federal Government requires that
supervisory personnel perform sufficient review to detect and eliminate
errors, and thus ensure that transactions are properly recorded and
adequately supported and that reports are properly prepared. 12 Contracting
out financial activities in support of year- end financial reporting does
not relieve IRS of its responsibility to maintain accurate records or to
adequately review financial information.

In fiscal year 2000, we found that IRS accepted information from its
contractors for inclusion in its year- end financial reporting without
sufficient oversight or review. For example, during fiscal year 2000 IRS
hired a contractor to extract and analyze from IRS? records major system
acquisitions and purchases to derive the amounts that it should capitalize
as P& E on its financial statements. IRS then recorded adjusting entries
provided by the contractor to transfer these P& E acquisitions to the
appropriate general ledger account. However, information provided by the
contractor was not always accurate and IRS did not review the data to ensure
their reliability. For example,

 8 of 60 transactions we tested, totaling $879,000, were inappropriately
identified by the contractor as P& E for fiscal year 2000, and two of the 8
transactions were actually purchases of P& E that should have been reported
in fiscal year 1999, while the remaining 6 transactions should have remained
as expenses, and

 the contractor?s calculation of fiscal year 2000 depreciation expense
totaling $359 million contained errors of $61 million (17 percent).

IRS had similar problems with contractor- developed adjustments for
undelivered orders. 13 In prior years and again in fiscal year 2000, we
found that IRS did not always reduce the balance of undelivered orders when
goods and services were received. This resulted in IRS overstating its
undelivered orders and understating its accrued expenses since IRS had
already received the goods and services and should have decreased its
undelivered orders accordingly. In response to a recommendation we made
after our fiscal year 1999 audit that IRS periodically analyze outstanding
balances to determine their status and whether any adjustments are
necessary, IRS hired a contractor to review its accrued expenses as of
September 30, 1999.

12 GAO/ AIMD- 00- 21.3.1, Nov. 1999. 13 Undelivered orders represent the
value of goods and services that were ordered and obligated but have not
been received.

GAO- 01- 880R IRS Management Letter Page 8 However, during our fiscal year
2000 audit, we noted that several of the contractordeveloped

adjustments were erroneous. We also found that IRS had accepted the
adjustments without reviewing them for appropriateness.

Financial information provided by contractors was not always correct, and
IRS did not detect the errors as a result of its lack of sufficient
oversight. This allowed uncorrected data to be included in the generation of
IRS? financial statements and, without audit adjustments, could have led to
erroneous information being reported by IRS.

Recommendation We recommend that you ensure that IRS personnel maintain
effective oversight of the completeness and accuracy of contractor-
generated information.

IRS? Comments and Our Evaluation In commenting on this section, IRS stated
that it reviewed the deliverables and supporting workpapers provided by the
contractor relating to property and equipment and made adjustments. IRS
further stated that it did not and should not be expected to review every
transaction to determine if an exception occurred. While we do not expect
that IRS should review every transaction, we do expect that effective review
and oversight should result in material problems being identified. Our
detailed testing of 60 transactions, in which we found 8 errors, was based
on a statistical sample. Based on our work, we estimate the most likely
overstatement of the P& E balance as a result of transactions incorrectly
recorded as fiscal year 2000 P& E was $61 million, with an upper error limit
of $106 million. This exceeded our test materiality. 14

IRS also stated that the other issue we raised with respect to P& E was the
result of a change we made to the life expectancy of certain assets. There
was no change in life expectancy of assets from fiscal year 1999 through
fiscal year 2000. However, we did find cases in which the contractor did not
correctly use the life expectancies established in fiscal year 1999.

With respect to the discussion of accrued expenses in this section, IRS
stated that it performed a thorough review of the contractor?s work in
reviewing accrued expenses as of September 30, 1999. However, we question
the adequacy of this review. We found that in a number of instances the
contractor did not go beyond summary level information in determining
accrual amounts. For example, IRS allocated $209,500 of the total invoice
cost of $260,130 related to an information services contract to fiscal year
1999, and the remaining $50,630 to fiscal year 2000. However, based on the
terms of the service contract, we determined that only $1,724 of the invoice
cost related to services for fiscal year 1999, while the remaining $258,406
related to services to be rendered in fiscal year 2000. It appears the
contractor did not go beyond the first page of the invoice in determining
the accrual amount, while the

14 Our estimate is based on a 95 percent confidence level and the use of a
test materiality of $87 million.

GAO- 01- 880R IRS Management Letter Page 9 supporting pages of the invoice
clearly broke out the fiscal year 1999 costs. In testing

a statistical sample of accrued expenses recorded at the end of fiscal year
1999, we identified errors in 36 percent of the sample cases. We believe an
appropriate review would have caught much of these errors.

IRS Needs to More Closely Adhere to Treasury Requirements Regarding
Transferring Funds Between Appropriations

During our fiscal year 2000 financial audit, we found that IRS did not
always follow standard procedures with respect to the transfer of funds
between appropriations. IRS recorded a transfer of budgetary authority 15 in
its general ledger before Treasury processed the transfer in response to
obtaining the congressional approval provided for in the Treasury Department
Appropriations Act, 2000. Section 2035 of the Treasury Financial Manual
(TFM) requires that agencies record such nonexpenditure transfers 16 in the
same month as they are processed by the Treasury.

During our fiscal year 2000 audit, we determined that IRS transferred funds
between accounts in its general ledger about 7 months before Treasury
processed the same transaction. Specifically, in October 1999, IRS
transferred appropriated amounts of $100 million out of the Tax Law
Enforcement fund balance account, of which $60 million was transferred to
the Processing, Assistance, and Management fund balance account and $40
million was transferred to the Information Systems fund balance account.

Section 101 of the Treasury Department Appropriations Act, 2000, provides
that up to 5 percent of an IRS appropriation may be transferred to another
IRS appropriation upon advance approval of the Senate and House Committees
on Appropriations. IRS, through Treasury, did not request this approval
until March 2000. The transfer was approved in April 2000, and Treasury
recorded the transfer in May 2000. However, IRS had administratively
recorded the transfer in its general ledger in October 1999- 7 months before
Treasury processed the transaction.

Although we did not identify any instances of IRS? expenditures exceeding
approved funding levels in fiscal year 2000, IRS violated section 2035 of
the TFM by recording the transfer of appropriations before the transfer was
processed by Treasury.

Recommendation We recommend that you direct IRS management to ensure that it
complies with Treasury regulations requiring that all transfers of funds
between appropriations be properly approved and documented prior to
recording them in the financial records.

15 Budgetary authority is the authority the Congress grants federal agencies
to incur obligations and to make payments out of the Treasury for specified
purposes. An appropriation act is the most common form of budgetary
authority.

16 Nonexpenditure transfers of appropriations increase or decrease
appropriation amounts between appropriation and fund accounts as a result of
legislation.

GAO- 01- 880R IRS Management Letter Page 10 IRS? Comments and Our Evaluation

IRS did not address the transfer of funds issue discussed in this section. -
- - - This letter contains recommendations to you. The head of a federal
agency is required by 31 U. S. C 720 to submit a written statement on
actions taken on these recommendations. You should submit your statement to
the Senate Committee on Governmental Affairs and the House Committee on
Government Reform within 60 days of the date of this letter. A written
statement must also be sent to the House and Senate Committees on
Appropriations with the agency?s first request for appropriations made more
than 60 days after the date of the letter.

This letter is intended for use by the management of IRS. We are sending
copies to Chairmen and Ranking Minority Members of the Senate Committee on
Appropriations; Senate Committee on Finance; Senate Committee on
Governmental Affairs; Senate Committee on the Budget; Subcommittee on
Treasury and General Government, Senate Committee on Appropriations;
Subcommittee on Taxation and IRS Oversight, Senate Committee on Finance; and
the Subcommittee on Oversight of Government Management, Restructuring, and
the District of Columbia, Senate Committee on Governmental Affairs. We are
also sending copies to the Chairmen and Ranking Minority Members of the
House Committee on Appropriations; House Committee on Ways and Means; House
Committee on Government Reform; House Committee on the Budget; Subcommittee
on Treasury, Postal Service, and General Government, House Committee on
Appropriations; Subcommittee on Government Efficiency, Financial Management,
and Intergovernmental Relations, House Committee on Government Reform; and
the Subcommittee on Oversight, House Committee on Ways and Means. In
addition, we are sending copies of this letter to the Chairman and Vice-
Chairman of the Joint Committee on Taxation, the Secretary of the Treasury,
the Director of the Office of Management and Budget, the Chairman of the IRS
Oversight Board, and other interested parties. Copies will be made available
to others upon request. The letter is also available on GAO?s homepage at
http:// www. gao. gov.

GAO- 01- 880R IRS Management Letter Page 11 We acknowledge and appreciate
the cooperation and assistance provided by IRS

officials and staff during our audit of IRS? fiscal year 2000 financial
statements. If you have any questions or need assistance in addressing these
matters, please contact Steven J. Sebastian, Acting Director, at (202) 512-
9521. Additional contacts and staff acknowledgments are provided in
enclosure II.

Sincerely yours, Jeffrey C. Steinhoff Managing Director Financial Management
and Assurance

Enclosures

Enclosure I GAO- 01- 880R IRS Management Letter Page 12

Comments From the Internal Revenue Service

Enclosure I GAO- 01- 880R IRS Management Letter Page 13

Enclosure I GAO- 01- 880R IRS Management Letter Page 14

Enclosure II GAO- 01- 880R IRS Management Letter Page 15

GAO Contacts and Staff Acknowledgments GAO Contacts

J. Lawrence Malenich, (202) 512- 9399 William J. Cordrey, (404) 679- 1873

Acknowledgments

Staff making key contributions to this letter were Paul Caban, John H.
Davis, Meafelia Gusukuma, Angel Sharma, and Leonard Zapata.

(191006)
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