Management Report: Review of Controls over Safeguarding Taxpayer 
Receipts and Information at the Brookhaven Service Center Campus 
(10-MAR-05, GAO-05-319R).					 
                                                                 
This report responds to a Congressional request that, in	 
conjunction with our audit of the Internal Revenue Service's	 
(IRS) fiscal year 2004 financial statements, we review the	 
agency's procedures for handling and processing receipts and	 
taxpayer information at the Brookhaven service center campus. As 
a result of the increased percentage of taxpayers filing returns 
electronically, IRS designed a detailed business plan to reduce  
the number of service center campuses that process paper returns.
In fiscal year 2004, Brookhaven became the first service center  
campus to downsize its submission processing function, leading to
changes in its operations and a significant reduction in the	 
volume of taxpayer receipts and information processed. Congress  
requested this review in light of these significant changes in	 
operations and IRS's desire to benefit from the Brookhaven	 
experience in planning for future submission processing 	 
rampdowns. Specifically, we were asked to (1) review the policies
and procedures IRS developed to safeguard and process taxpayer	 
receipts and information at the modified Brookhaven operation and
(2) offer recommendations, if any, for improving internal	 
controls at Brookhaven and at other submission processing centers
that will undergo future rampdowns. To accommodate the request,  
we agreed to add a review of the mail control function at the	 
Brookhaven service center campus to our tests of internal	 
controls conducted as part of our audit of IRS's fiscal year 2004
financial statements. We have performed extensive work in	 
reviewing internal controls designed to safeguard taxpayer	 
receipts and information as part of our annual financial audits  
of IRS. In performing this work, we have come to recognize the	 
significance and importance of the submission processing function
to IRS and the potential for loss, theft, or misuse of taxpayer  
receipts and information if controls are not properly designed	 
and effectively implemented. Our audits have identified 	 
weaknesses in internal controls over the safeguarding of taxpayer
receipts and information related to submission processing	 
activities at IRS's service center campuses, lockbox banks, and  
field offices. In reviewing the Brookhaven rampdown procedures,  
we considered the internal control weaknesses previously found at
other service center campuses.					 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-319R					        
    ACCNO:   A19116						        
  TITLE:     Management Report: Review of Controls over Safeguarding  
Taxpayer Receipts and Information at the Brookhaven Service	 
Center Campus							 
     DATE:   03/10/2005 
  SUBJECT:   Data integrity					 
	     Electronic government				 
	     Internal controls					 
	     Policy evaluation					 
	     Tax administration 				 
	     Tax information confidentiality			 
	     Tax returns					 
	     Taxpayers						 
	     Policies and procedures				 

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GAO-05-319R

United States Government Accountability Office Washington, DC 20548

March 10, 2005

John M. Dalrymple
Deputy Commissioner for Operations Support
Internal Revenue Service

Subject:	Management Report: Review of Controls over Safeguarding Taxpayer
Receipts and Information at the Brookhaven Service Center Campus

Dear Mr. Dalrymple:

This report responds to your request that, in conjunction with our audit
of the Internal Revenue Service's (IRS) fiscal year 2004 financial
statements,1 we review the agency's procedures for handling and processing
receipts and taxpayer information at the Brookhaven service center campus.
As a result of the increased percentage of taxpayers filing returns
electronically, IRS designed a detailed business plan to reduce the number
of service center campuses that process paper returns. In fiscal year
2004, Brookhaven became the first service center campus to downsize its
submission processing function, leading to changes in its operations and a
significant reduction in the volume of taxpayer receipts and information
processed.2 You requested this review in light of these significant
changes in operations and IRS's desire to benefit from the Brookhaven
experience in planning for future submission processing rampdowns.3
Specifically, you asked us to (1) review the policies and procedures IRS
developed to safeguard and process taxpayer receipts and information at
the modified Brookhaven operation and (2) offer recommendations, if any,
for improving internal controls at Brookhaven and at other submission
processing centers that will undergo future rampdowns. To accommodate your
request, we agreed to add a review of the mail control function at the
Brookhaven service center campus to our tests of internal controls
conducted as part of our audit of IRS's fiscal year 2004 financial
statements.

As you are aware, we have performed extensive work in reviewing internal
controls designed to safeguard taxpayer receipts and information as part
of our annual

1GAO, Financial Audit: IRS's Fiscal Years 2004 and 2003 Financial
Statements, GAO-05-103

(Washington, D.C.: Nov. 10, 2004).
2Submission processing is the data processing arm of IRS. These units
process paper and electronic
submissions at IRS service center campuses. This includes depositing tax
payments, correcting errors,
and forwarding data to IRS's computing centers for analysis and posting to
taxpayer accounts.
3In this report, the term "rampdown" is used to refer to IRS's significant
reduction of its submission
processing functions at selected service center campuses.

financial audits of IRS.4 In performing this work, we have come to
recognize the significance and importance of the submission processing
function to IRS and the potential for loss, theft, or misuse of taxpayer
receipts and information if controls are not properly designed and
effectively implemented. Our audits have identified weaknesses in internal
controls over the safeguarding of taxpayer receipts and information
related to submission processing activities at IRS's service center
campuses, lockbox banks,5 and field offices. In reviewing the Brookhaven
rampdown procedures, we considered the internal control weaknesses
previously found at other service center campuses.

We performed most of our work from May 2004 through October 2004 as part
of our audits of IRS's fiscal years 2004 and 2003 financial statements,
with some additional follow-up work completed in January 2005. 6 We
designed our tests and inquiries based on results and findings from our
previous years' audits and financial management-related reviews, taking
into consideration differences that may occur during a nonpeak tax filing
season and the nature of Brookhaven's ramped down operations. We conducted
our work in accordance with U.S. generally accepted government auditing
standards. Additional details on our scope and methodology are included in
our fiscal year 2004 financial statement audit report.7

Results in Brief

We found that IRS completed the rampdown at Brookhaven without any
significant disruptions in service. However, we did identify several areas
where improvements could be made to internal controls at the Brookhaven
service center campus residual mail processing unit, as well as to the
process for estimating mail volumes. These issues are also relevant to IRS
as it proceeds in ramping down future submission processing functions.

Specifically, we found the following:

o  	IRS developed standard operating procedures for employees processing
incoming mail at Brookhaven during the rampdown. However, we found that
these procedures did not include detailed instructions for (1) tracking
taxpayer receipts and information forwarded to other service center
campuses for further processing and (2) handling cash receipts found
during the extraction process. The absence of these instructions increases
the risk that employees with significant internal control responsibilities
over high-risk and vulnerable assets are not aware of the correct
procedures to be followed in safeguarding and

4GAO, Internal Revenue Service: Status of Recommendations from Financial
Audits and Related
Financial Management Reports, GAO-04-523 (Washington, D.C.: Apr. 28,
2004).
5Lockbox banks are financial institutions designated as depositories and
financial agents of the U.S.
government to perform certain financial services, including processing tax
documents, depositing the
receipts, and then forwarding the documents and data to IRS's service
center campuses, which update
taxpayers' accounts.
6As agreed, we visited Brookhaven in May 2004 after the peak tax filing
season, which primarily occurs
from January 1 through April 15 of each year when most individual tax
returns are filed.
7GAO-05-103.

processing taxpayer receipts and information, thereby increasing the risk
of their theft, loss, or misuse.

o  	Staff at the Brookhaven location did not always follow the required
procedures to safeguard taxpayer receipts and information in its
facilities. We found that (1) access rights allowed to visitors were not
always appropriately restricted; (2) trash, which included taxpayer
information, was not always sufficiently secured; and (3) candling8 was
not always properly performed. The lack of adherence to IRS's procedures
increases the risk of theft, loss, or misuse of taxpayer receipts and
information.

o  	IRS did not have a documented methodology for estimating post-rampdown
mail volumes at service center campuses selected for rampdowns. The lack
of a documented methodology increases the risk that adequate mail volume
information will not be gathered, maintained, and appropriately considered
as estimates are prepared to assist IRS management in making decisions
related to sites selected for future rampdowns and assessing their
ultimate success.

This report offers three recommendations to assist IRS with strengthening
controls over the safeguarding of taxpayer receipts and information and
preparing for future rampdowns. In its comments, IRS agreed with our
recommendations and described actions that it had taken or planned to take
to address the issues described in this report.

Scope and Methodology

In conducting our review of the Brookhaven submission processing function,
we did the following:

o  	Visited the Brookhaven service center campus from May 24 through May
27, 2004, and observed mail operations over taxpayer receipts and
information.

o  	Conducted interviews with IRS and U.S. Treasury Inspector General for
Tax Administration officials regarding the phaseout of the submission
processing function.

o  	Gathered and analyzed data outlining IRS's planning and implementation
processes for the Brookhaven rampdown.

o  	Reviewed data covering fiscal year 2004 mail volumes, IRS's summary of
lessons learned from the rampdown, and strategies for ramping down future
submission processing functions.

8Candling is a process used by IRS to determine if any contents remain in
open envelopes. This is often achieved by passing the envelopes over a
light source.

Background

On July 22, 1998, Congress enacted the IRS Restructuring and Reform Act of
1998 (RRA 98)9 to better balance IRS's responsibility to collect taxes,
protect the rights of taxpayers, and serve the public. Among other
provisions, RRA 98 authorized IRS to encourage the use of its electronic
tax administration programs by taxpayers to reach the goal of 80 percent
of individual tax returns filed electronically by 2007. IRS has strongly
encouraged taxpayers to file electronically and acted to facilitate and
support this transition. Although IRS does not expect to achieve the goal
set by RRA 98, substantial progress has been made. From 1998 to 2004, the
volume of paper returns decreased by 30 million returns-from 101 million
in 1998 to 71 million in 2004 (over 29 percent). IRS reported that during
the 2004 filing season, 47 percent of individual tax returns were filed
electronically. As part of its approach to administering and managing this
change in taxpayer behavior, IRS developed and approved a detailed
business plan to gradually reduce the number of its submission processing
functions that process individual and business tax returns. The plan calls
for the rampdown of a submission processing function every few years until
this function remains at only four service center campuses (SCC). The pace
of implementation depends on the public's continued migration from paper
to electronically filed returns.

Prior to rampdown, Brookhaven performed functions generally similar to the
other 9 IRS SCCs in the processing of taxpayer receipts and information.
All 10 SCCs also managed taxpayer accounts and compliance programs. The
functions performed by SCCs included (1) opening, sorting, and extracting
mail; (2) depositing payments; (3) posting data to IRS's financial
management systems; and (4) reconciling deposits to deposit information
maintained at the Department of the Treasury's Financial Management
Service. In connection with the Brookhaven rampdown, IRS instructed
taxpayers and tax preparers who previously submitted their returns to the
Brookhaven SCC to instead send their returns, payments, or both to other
specifically designated locations.

Despite IRS's instructions designating other locations to which returns
were to be sent, some taxpayers continue to mail tax returns and receipts
to the Brookhaven location. Mail arriving at the Brookhaven SCC, including
some taxpayer returns, payments, correspondence, notices, and mail
returned to IRS as undeliverable, is now handled by a newly created unit
within Brookhaven, the Accounts Management Mail Unit. This unit is tasked
with the goal of timely performing the initial mail processing, including
extracting, dating and recording, sorting, and candling. The receipts and
tax returns are then forwarded overnight to either the Andover or
Cincinnati SCCs for further processing, depending on the type of return
involved.10

9IRS Restructuring and Reform Act of 1998, Pub. L. No. 105-206, 112 Stat.
685 (July 22, 1998). 10Individual returns and payments are forwarded to
the Andover SCC and business returns and payments are forwarded to the
Cincinnati SCC.

No Major Disruptions in Brookhaven Operations during Its Submission
Processing Rampdown

During fiscal year 2004, IRS implemented its rampdown of the Brookhaven
SCC submission processing function with no major disruptions in service.
As part of this success, the Brookhaven SCC exceeded its goal of sending
taxpayer receipts and returns for further processing to either of the two
other designated SCCs within 3 to 5 workdays from time of receipt in
Brookhaven, generally accomplishing this task within 48 hours. IRS's
ability to successfully realize its rampdown is attributable in part to
(1) early planning, which began as far back as 1998; (2) initiatives that
the personnel office undertook to ensure minimum impact to the taxpayers
and IRS's employees; and (3) involvement of the necessary business
divisions, offices, units, and managers from its functional areas,
including operations, communications, infrastructure (i.e., equipment and
real estate), and personnel.

IRS's planning efforts were critical because the rampdown had a dramatic
impact on Brookhaven SCC operations and its personnel. For example, the
rampdown necessitated the agency's first reduction in force,11 affecting
more than 2,700 employees previously assigned to the campus's submission
processing function. Of those employees, 664 were actually laid off. The
remaining employees were reassigned to other jobs, took advantage of
voluntary retirement or separation incentives, or resigned from their
jobs. As of January 2005, 127 employees were assigned to processing
incoming mail in the Brookhaven Accounts Management Mail Unit.

IRS continues to plan for future rampdowns12 through the following
strategies: (1) gaining consensus from its managers and employees on how
to approach future rampdowns, (2) identifying areas of improvement based
on the implementation of the Brookhaven SCC rampdown, (3) documenting and
evaluating common consolidating themes and lessons learned, and (4)
incorporating those lessons learned into future rampdown implementation
plans. As IRS proceeds with the implementation of its detailed business
plan to reduce the number of SCCs that process paper returns, it is
critical that effective internal controls are maintained to deal with the
unique risks entailed in the changing submission processing environment.

Certain Procedures Could Be Strengthened as IRS Pursues Future Rampdowns

While we want to emphasize that IRS's rampdown of the Brookhaven
submission processing function was achieved with no major service
disruptions, our review identified certain matters that should be
addressed to provide for better safeguarding of taxpayer receipts and
information and better efficiency in the processing and monitoring of
residual returns and receipts at Brookhaven and at future rampdown
locations. Specifically, we identified three areas where IRS's procedures
could be strengthened: (1) instructions and guidance to staff processing
mail, (2) adherence to

11In the federal government, layoffs are called reductions in force.
12IRS plans to ramp down the Memphis and Philadelphia submission
processing functions during fiscal
years 2005 and 2007, respectively.

existing management controls, and (3) procedures for estimating future
mail volume data. Each of these areas is relevant to operations at other
SCCs and to IRS's success as it proceeds with future rampdowns.

Instructions and Guidance to Staff Processing Mail

Recognizing the change required in the Brookhaven Accounts Management Mail
Unit operations to process residual returns and receipts received during
and after the rampdown, IRS developed specific standard operating
procedures (SOP) to instruct and guide mail room staff. We noted that the
SOPs could be strengthened by including specific instructions for (1)
monitoring document transmittals after receipts and tax returns were
forwarded to another SCC for final processing and (2) processing cash
discovered during the extraction process. The absence of such instructions
in the Brookhaven SOPs increases the risk that employees are not familiar
with how to safeguard, process, and account for taxpayer receipts and
information. We did note that instructions related to these two areas did
exist in various sections of IRS's Internal Revenue Manual (IRM)13 related
to submission processing. However, the Brookhaven SOPs that were used to
guide staff on a daily basis were silent on these tasks and did not
contain a reference to these requirements in the IRM.

Specifically, the SOP that outlines the procedures for preparing and
mailing taxpayer receipts and information received between SCCs did not
include instructions for the Accounts Management Mail Unit to timely
verify that taxpayer receipts and information it had sent to other SCCs
had been received in their entirety by the receiving SCCs. While we found
instructions in the IRM addressing the monitoring of document transmittals
used to mail items between IRS locations, these instructions were not
available or referred to in the SOP. For instance, according to the Case
Processing section of the IRM, IRS staff sending taxpayer receipts,
returns, and information to SCCs are required to establish a control to
ensure that the contents of packages were received. The IRM states that
the receiving SCC must acknowledge receipt of package contents within 5
workdays. If no acknowledgment is received, the sender must initiate
follow-up within 10 workdays. However, similar procedures for the Accounts
Management Mail Unit staff were not outlined or mentioned in the SOP.
Neither the IRM's Case Processing section nor the SOP includes
instructions for matching receipt acknowledgments to the original list of
contents sent. Without these controls, the risk is increased that lost
documents will not be promptly identified and affected taxpayers alerted
timely.

Illustrating this issue, during our site visit to the Brookhaven SCC, we
found a basket in the Accounts Management Mail Unit that contained several
weeks of acknowledged document transmittals from the Andover and
Cincinnati SCCs that had not yet been matched to the original document
transmittals. Without timely matching of the original copies of the
document transmittals to the acknowledged ones, IRS management could not
be timely assured that documents or packages (including

13The IRM is IRS's internal operating manual that sets forth the agency's
various operating polices and procedures.

payments and returns) sent from the Brookhaven SCC actually reached their
destinations. While Brookhaven staff stated that e-mails were received
from the designated SCCs, the e-mails only acknowledged receipt of the
packages and not the full extent of their contents.

We also found that the SOPs did not include guidance on the processing of
cash discovered during the extraction process. While the IRM contains
detailed guidance for handling cash discovered during extraction, these
instructions were not outlined or referred to in the SOP. Cash is not
commonly used by taxpayers to make payments through the mail; however, we
have observed cash payments submitted by taxpayers through the mail in
prior audits. Consequently, because employees do not have clear guidance
regarding the handling of cash, the risk is increased that such cash might
be lost or misappropriated.

During our review, we were informed that IRS plans to add the SOPs used by
the Brookhaven Accounts Management Mail Unit to its IRM. The IRM will then
be the general guide used for all other Accounts Management Mail Unit
operations created as IRS continues with its plans for future submission
processing consolidations.

Adherence to Existing Management Controls

During our visit to Brookhaven, we tested selected controls intended to
safeguard taxpayer receipts and information. As agreed with IRS, our visit
took place in May 2004, a nonpeak period during which mail volume was
lower and less processing was observed. Nonetheless, we found three
instances where IRS employees did not adhere to the policies and
procedures IRS currently has in place.

o  	IRS requires that individuals inside any restricted area wear badges
indicating access was granted. Such badges are to be worn only while in
these areas and are required to be relinquished upon departure. However,
after leaving a secured area, we were mistakenly given other badges with
access rights to secured areas.

o  	According to IRS standards, taxpayer data and related information no
longer needed must be destroyed through a secure process such as
shredding. While these items are awaiting destruction, IRS must protect
the items from improper disclosure. However, we observed sensitive waste
containing taxpayer information, such as undeliverable mail, computer
screen printouts, and photo copies of incorrect document transmittals,
stored on a loading dock in an unlocked container for periods of up to 2
weeks prior to disposal.14 While the loading dock was within a secured
perimeter, employees, contractors, and visitors allowed in this area could
have gained unauthorized access to this sensitive information.

14IRS officials told us that pickups for these items are normally
scheduled on a biweekly basis.

o  	To prevent the accidental destruction of taxpayer receipts and
information, IRS requires that emptied envelopes be candled twice before
destruction to ascertain that all contents were removed. However, we
observed one IRS employee who did not run the envelopes over the light
source to complete the first candling.

Although the lack of adherence to these policies and procedures created no
major disruption in service or hindrance to IRS's processing of mail
received at the Brookhaven SCC, it increases the risk that taxpayer
receipts and information will be unnecessarily exposed to potential loss,
theft, or misuse.

Procedures for Estimating Mail Volume Data

IRS's plan to ramp down its submission processing function is in direct
response to the continuing decline in the volume of paper returns and
receipts filed as taxpayers increasingly migrate to electronic filing. In
effecting a rampdown at a specific SCC, volume of incoming hard-copy
returns and receipts should normally decline dramatically over a short
period of time as taxpayers are instructed to mail these returns and
receipts to other locations. The rapid reduction in the volume of this
type of mail inevitably requires significant changes in operating
procedures and staffing levels. Detailed procedures documenting how to
accumulate and utilize mail volume data are thus necessary to better
enable IRS to estimate post-rampdown volume and measure the rampdown's
success. However, during our review, we did not find a documented
methodology for estimating mail volumes that was tailored to encompass the
dramatic changes in mail volume precipitated by a rampdown.

Each year, IRS develops an annual plan that estimates the numbers and
types of returns and receipts to be filed at each SCC during the upcoming
tax filing season. This process considers such factors as prior years'
experience and processing, legislative, and budget changes. These
estimates are used to assist IRS in determining the staffing needs of each
SCC during routine operations when mail volume levels are relatively
stable. However, this process is not designed to provide for the
dramatically lower mail volumes expected in a rampdown. For example,
according to IRS, during fiscal year 2002, Brookhaven processed about 26.8
million pieces of mail. In contrast, during fiscal year 2004, Brookhaven
processed about 3.4 million pieces of mail, a decrease of over 87 percent
from its pre-rampdown level.

In reviewing the mail volume data maintained at the Brookhaven SCC after
its rampdown, which included estimates and actual pieces of mail received,
we found that staff were not provided with a methodology to assist them in
compiling Brookhaven's post-rampdown mail volume estimates. The lack of a
documented methodology for estimating mail volume data at SCCs selected
for a rampdown could affect IRS's ability to develop sound and reliable
mail volume estimates that can be used as a tool to assist in implementing
and assessing the success of future rampdowns. This increases the risk
that IRS management will not have reliable data available to effectively
manage its resources during and after each rampdown or to evaluate its
success.

Conclusions

IRS succeeded in ramping down the submission processing function at the
Brookhaven SCC without any major disruption of operations. The completion
of such a significant restructuring of a large and complex operation like
an SCC without major service disruptions is a notable accomplishment.
Nonetheless, opportunities exist for IRS to enhance its internal controls
over the safeguarding of hard-copy taxpayer receipts and information at
Brookhaven and future rampdown locations. IRS will inevitably experience
similarly significant changes in mail volume at other SCCs as it proceeds
with implementing its detailed business plan. To maximize the benefit IRS
realizes from its Brookhaven experience will require a systematic,
documented approach to analyzing and utilizing mail volume information and
effectively applying it to planning for and assessing the success of
future rampdowns.

Recommendations for Executive Action

To address the issues we have raised in this report to assist in both
strengthening controls at the Brookhaven SCC and in the planning and
implementation of future SCC rampdowns, we recommend that IRS do the
following:

o  	Revise the Accounts Management Mail Unit procedures, scheduled to be
incorporated into the IRM, to include detailed instructions for (1)
monitoring transshipped documents and (2) handling cash receipts found
during extraction. Where adequate guidance exists elsewhere, IRS should
include these through cross-references.

o  	Enforce adherence to existing instructions on safeguarding taxpayer
receipts and information, such as securing access and candling procedures,
at SCCs selected for significant reductions in their submission processing
functions.

o  	Document a methodology for estimating anticipated rapid changes in
mail volume at future SCCs selected for significant reductions in their
submission processing functions, taking into consideration factors such as
the prior rampdown experience at Brookhaven.

Agency Comments

We received written comments on a draft of this report from IRS's
Commissioner. In commenting on our draft report, IRS's Commissioner agreed
with our recommendations and described actions that the agency had taken
or planned to take to improve the planning, procedures, and residual work
processes associated with future rampdowns. The IRS Commissioner's
comments are reproduced in their entirety in the enclosure to this report.

This report contains recommendations to you. We would appreciate receiving
a description and status of your corrective actions within 30 days of the
date of this report.

This report is intended for use by the management of IRS. We are sending
copies to the Chairmen and Ranking Minority Members of the Senate
Committee on Appropriations; Senate Committee on Finance; Senate Committee
on Homeland Security and Governmental Affairs; Senate Committee on the
Budget; Subcommittee on Transportation and Treasury and General
Government, Senate Committee on Appropriations; Subcommittee on Taxation
and IRS Oversight, Senate Committee on Finance; Subcommittee on Oversight
of Government Management, the Federal Workforce, and the District of
Columbia, Senate Committee on Homeland Security and Governmental Affairs;
House Committee on Appropriations; House Committee on Ways and Means;
House Committee on Government Reform; House Committee on the Budget;
Subcommittee on Transportation, Treasury, and Housing and Urban
Development, The Judiciary, District of Columbia, House Committee on
Appropriations; Subcommittee on Government Management, Finance, and
Accountability, House Committee on Government Reform; and Subcommittee on
Oversight, House Committee on Ways and Means. In addition, we are sending
copies of this report to the Chairman and Vice Chairman of the Joint
Committee on Taxation, the Commissioner of Internal Revenue, 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. In addition, the report is available at no charge on
GAO's Web site at http://www.gao.gov.

We acknowledge and appreciate the cooperation and assistance provided by
IRS officials and staff during our review. If you have any questions or
need assistance in addressing these matters, please contact me at (202)
512-3406 or [email protected]. Key contributors to this assignment were
Charles Fox, Alain Dubois, John Sawyer, and Gary Wiggins.

Sincerely yours,

Steven J. Sebastian
Director
Financial Management and Assurance

Enclosure

Enclosure

                   Comments from the Internal Revenue Service

                                   Enclosure

                                   Enclosure

                                    (196024)

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