Tax Administration: IRS Efforts to Improve Forms and Publications (Letter
Report, 12/07/94, GAO/GGD-95-34).

Providing taxpayers with easy-to-read forms and publications is a
difficult task.  The Internal Revenue Service (IRS) must strike a
balance between the need for these documents to reflect a highly complex
tax code and the need to make these documents understandable and
easy-to-read. Although it faces many challenges in developing and
revising forms and publications, IRS has instituted a process for doing
so that includes reasonable components and is seeking ways to further
improve it.  IRS has begun a dialogue with groups representing tax
professionals, but it has had problems in identifying and responding to
the needs of individual taxpayers who are not represented by any
professional organization. Because clear and understandable forms help
to promote voluntary compliance, readability is a continuous concern.
Thus, IRS should continue to seek ways to identify what individual
taxpayers find most difficult to understand.  IRS should also explore
the use of potentially useful, but untapped, sources of information that
may reveal points of taxpayer confusion and use existing information in
new ways.

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

 REPORTNUM:  GGD-95-34
     TITLE:  Tax Administration: IRS Efforts to Improve Forms and 
             Publications
      DATE:  12/07/94
   SUBJECT:  Tax returns
             Taxpayers
             Federal forms
             Tax administration
             Income taxes
             Government publications
             Forms (documents)
             Information dissemination operations
             Telephone communications operations
             Tax law
IDENTIFIER:  IRS Business Master Plan
             
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Cover
================================================================ COVER


Report to the Chairman, Subcommittee on Oversight, Committee on Ways
and Means, House of Representatives

December 1994

TAX ADMINISTRATION - IRS EFFORTS
TO IMPROVE FORMS AND PUBLICATIONS

GAO/GGD-95-34

Forms and Publications Improvement

(268660)


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

  IRS - Internal Revenue Service
  OMB - The Office of Management and Budget
  TFCC - Tax Forms Coordinating Committee

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


B-259234

December 7, 1994

The Honorable J.J.  Pickle
Chairman, Subcommittee on Oversight
Committee on Ways and Means
House of Representatives

Dear Mr.  Chairman: 

This is the second of two reports in response to your concerns
regarding the accuracy and clarity of Internal Revenue Service (IRS)
forms and publications.  Providing taxpayers with tax guidance that
is readable and understandable is one way of promoting voluntary
compliance, the cornerstone of the federal income tax system. 

In our first report, which examined the clarity and accuracy of a
group of commonly used forms and publications, we made specific
suggestions to improve the clarity of 12 forms and 2 publications.\1
We did not identify any instances in which these documents did not
conform with current legal requirements or IRS guidance.  As agreed
with the Subcommittee, this report presents our evaluation of IRS'
forms and publications development and revision process, identifies
IRS' efforts to improve this process, and identifies IRS' initiatives
to increase taxpayers' involvement in this process. 


--------------------
\1 Tax Administration:  Selected IRS Forms, Publications, and Notices
Could be Improved (GAO/GGD-93-72, Apr.  30, 1993). 


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

Providing taxpayers with easy-to-read tax forms and publications is a
difficult task.  IRS must strike a balance between the need for these
documents to accurately reflect a highly complex tax code and the
need to make these documents understandable and easy-to-read. 
Finding this balance is an ongoing process as the tax code is
frequently revised, necessitating corresponding changes in forms and
publications.  Other factors, such as the wide range of taxpayers'
reading abilities, further complicate IRS' task. 

IRS' process for developing and revising its forms and publications
appears reasonable in that it provides for:  clear lines of
responsibility and accountability, specific timeframes, adequate
management oversight, sufficient opportunities to evaluate
suggestions from internal and external sources, and appropriate
strategies for coping with sudden tax law changes. 

Many forms and publications are revised annually, often under short
time constraints, and in response to tax law changes.  IRS
periodically reviews these documents and, when appropriate, schedules
them for revision.  IRS' procedures provide for incorporating tax law
changes into the revision process so that accurate forms and
publications are available to taxpayers in time for the filing
season.  IRS' procedures also include consideration of comments from
taxpayers regarding clarity improvements.  Such comments are
typically received from professional organizations representing such
interests as tax preparers, payroll professionals, accountants, and
lawyers. 

In an effort to further improve its forms and publications, IRS has
initiated several special projects to enhance their clarity.  For
example, IRS' Compliance Research Division is studying 10 factors
affecting taxpayers' comprehension of tax documents.  IRS intends to
use this information to prepare forms and instructions that taxpayers
will find easier to understand.  Another effort emanates from IRS'
recently issued Business Master Plan.  Under this plan,
simplification teams are to be established with staff from IRS field
offices.  These teams will be charged with taking a fresh look at
selected forms each year and offering specific recommendations to the
Tax Forms and Publications Division.  These and other projects attest
to the agency's stated interest in continuous improvement. 

Despite IRS' process for developing forms and publications and its
stated ongoing commitment to improvement, IRS recognizes that it has
no systematic way to determine what individual taxpayers specifically
find confusing about forms and publications.  While IRS has
established a dialogue with professional organizations regarding
their concerns with these tax documents, IRS is still trying to find
a way to readily identify the specific concerns of individuals.  We
believe IRS may already have data that could help it identify areas
that individual taxpayers are specifically having difficulty
understanding.  These potential sources of data include information
from IRS' toll-free telephone assistance program and field personnel
such as auditors and customer-service representatives. 


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

To implement a changing and highly technical tax code, IRS publishes
approximately 400 tax forms and accompanying instructions each year. 
More detailed guidance is provided in approximately 100 different
publications.  Frequent changes to the tax laws necessitate revisions
to both forms and publications.  The development and revision of tax
forms and their accompanying instructions and publications are the
responsibility of IRS' Tax Forms and Publications Division.  This
division is made up of two branches, the Forms Branch and the
Publications Branch. 

Tax forms and instructions are written by tax law specialists in the
Forms Branch.  Proposed new forms are reviewed by IRS' Tax Forms
Coordinating Committee (TFCC), which represents all major
organizational units in IRS.  TFCC provides a forum for all key IRS
functions to help ensure that forms meet the overall needs of the
agency without placing excessive burden on taxpayers.  All new forms
and major revisions to existing forms must be approved by TFCC.  IRS'
Chief Counsel must also approve the forms to ensure their technical
accuracy and consistency with laws and regulations.  The Office of
Management and Budget (OMB) is responsible for reviewing each tax
form once every 3 years.  The purpose of OMB's review is to assess
IRS' compliance with the Paperwork Reduction Act.  Among other
things, this law compels OMB to evaluate the extent of burden imposed
by IRS forms and to ensure that the federal paperwork burden for
individuals is minimized.  As a consequence, all new forms and major
revisions to existing forms must also be reviewed by OMB. 

Tax law specialists in the Publications Branch write and revise
publications.  Some publications are designed to accompany specific
forms, while others provide general information relating to a variety
of forms.  Because publications supplement information on forms and
instructions, they are not subject to TFCC review or OMB approval. 
Publications are also periodically revised to reflect changes to the
tax laws or forms.  Each year, some publications are substantively
revised through an intensive review by a team that includes tax law
specialists, writer-editors, and technical reviewers associated with
the publication's subject matter.  These publications are
subjectively selected on the basis of circulation and the need for
text revision.  The objective of this revision is to make a major
improvement in the quality and usefulness of the publication. 

In 1978, we issued a report citing the tension between IRS'
conflicting responsibilities to develop forms that are technically
accurate, yet clear and readable.\2 In that report, we noted that
writer-editors and graphic experts played a limited role in the
development of only a few forms and that, as a result, technical
accuracy was favored at the expense of clarity.  While acknowledging
the importance of being accurate, we reported that the readability of
these documents needed improvement.  Our report recommended that IRS
institutionalize a broader mix of writing and graphics design experts
in a continuous review of forms and instructions.  Since then, IRS
has made greater use of its writer-editors and included more graphics
in its forms and publications. 


--------------------
\2 Further Simplification of Income Tax Forms and Instructions Is
Needed And Possible (GAO/GGD-78-74, July 5, 1978). 


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

Our objectives were to (1) evaluate IRS' forms and publications
development and revision process, (2) identify IRS' efforts to
improve this process, and (3) identify IRS' initiatives to increase
involvement of taxpayers in this process. 

To assess IRS' process for developing and revising forms and
publications, we examined the agency's written procedures and
discussed them with representatives from IRS' Tax Forms and
Publications Division, the unit with primary responsibility for
issuing these documents.  We also selected four forms and two
publications and tracked their progress through the development and
revision phase.  We included forms and publications used by
individuals and businesses as well as newly created forms and
existing forms undergoing revision.  To verify IRS' written
procedures and information obtained from IRS officials, we identified
the actual steps taken in producing these documents and compared
these activities to established procedures. 

To evaluate the reasonableness of IRS' process for developing and
revising forms and publications, we considered whether its procedures
provided for clear lines of responsibility and accountability,
specific timeframes, adequate management oversight, sufficient
opportunities to evaluate suggestions from internal and external
sources, and appropriate strategies for coping with sudden tax law
changes.  We also interviewed IRS officials involved in preparing
these documents and asked them to discuss the development and
revision process. 

To identify IRS' efforts to improve the process and to increase
taxpayers' involvement in it, we interviewed IRS officials.  In
addition, we met with OMB officials to discuss OMB's role in
reviewing tax forms for compliance with the Paperwork Reduction Act. 
We also met with representatives from external professional
organizations, which are concerned with the clarity and accuracy of
IRS forms and publications.  Our discussions with these groups
focused on their perceptions of IRS' willingness to hear their views
and to maintain a professional dialogue on matters affecting IRS
forms and publications.  Appendix I lists these organizations.  We
also discussed agency initiatives to improve the clarity of tax forms
and publications with various IRS officials involved in managing
these activities. 

We did our work at IRS' National Office in Washington, D.C., from
August 1993 to April 1994 in accordance with generally accepted
auditing standards.  We presented a draft version of this report to
appropriate IRS officials including the Chief of Strategic Planning
and Communications and the Director of the Tax Forms and Publications
Division and obtained oral comments from them on October 25, 1994. 
IRS' comments and our evaluation are on page 11 of this report. 


   IRS FACES CONTINUOUS CHALLENGE
   IN KEEPING FORMS AND
   PUBLICATIONS ACCURATE AND
   READABLE
------------------------------------------------------------ Letter :4

IRS' forms and publications are based on a complex and frequently
changing tax code.  Since 1980, Internal Revenue Code sections have
been amended more than 100 times, resulting in numerous modifications
to existing forms and the development of nearly 100 new ones.  This
combination presents a great challenge to IRS, which is expected to
issue documents that are not only technically accurate but readable. 
IRS is responsible for responding to changes in the tax law by
modifying forms and publications and issuing forms on a timely basis. 

In addition to revisions caused by changes in tax law, IRS reviews
all forms for possible revision on a periodic basis.  Many forms,
such as the Form 1040, "U.S.  Individual Income Tax Return," are for
use during a particular tax year and must be updated annually.  Other
forms, such as the Form 709, "United States Gift (and Generation
Skipping Transfer) Tax Return," may have an extended period of use. 
IRS automatically considers all forms for revision every 3 years
before sending them to OMB for review under the Paperwork Reduction
Act.  According to IRS officials, the agency currently publishes
approximately 400 forms of which about 80 percent are revised each
year. 

Factors beyond IRS' control may complicate its ability to provide
clear forms and publications.  Its role as a data gatherer for
research purposes may have a direct bearing on form clarity.  Some
forms may include lines requesting information unrelated to
computation of the tax.  This information may be gathered for valid
statistical or research purposes, but the information may have no
bearing on tax liability.  These lines may also be intended to aid an
IRS examiner conducting an audit.  Although these data collection
efforts may bear no relationship to tax liability and may actually
increase taxpayer burden, they may also serve valuable purposes
justifying their presence.  In addition, the varying literacy levels
of taxpayers, the many forms and publications and their relationships
to each other, and the sheer number of annual changes, even those
adopted for the sake of clarity, can further contribute to general
confusion among taxpayers. 


   COMPONENTS OF IRS' PROCESS FOR
   DEVELOPING AND REVISING FORMS
   AND PUBLICATIONS APPEAR
   REASONABLE
------------------------------------------------------------ Letter :5

We found that IRS' process for developing new forms and publications
and revising existing ones is composed of reasonable components.  For
example, its procedures (1) establish well-defined roles and
responsibilities for staff, clear lines of accountability, and
specific timeframes for drafting these documents and (2) ensure
sufficient management oversight.  In addition, the procedures provide
steps to accommodate the passage of legislation late in the calendar
year.  IRS officials involved in this process identified no major
problems with agency procedures that would hamper their ability to
create and revise forms and publications, and the officials were
generally satisfied with the procedures.  Representatives from the
professional organizations we interviewed also were generally
satisfied with IRS' process.  Our tracking of four forms and two
publications also indicated that IRS' procedures were followed and
proved reasonable. 

IRS has taken steps to build greater readability into its development
and revision process since we issued our prior report in 1978. 
Greater use is now being made of writer-editors.  While
writer-editors were rarely used at the time of our previous report,
they now play an integral role in simplifying language and assisting
in the development of suitable graphic presentations intended to
enhance readers' understanding. 

As part of its annual revisions process, IRS obtains suggestions for
improving both the accuracy and clarity of its forms and publications
from a variety of internal and external sources such as organizations
representing tax professionals and tax preparers, taxpayers, and
employees.  All suggestions are to be referred to an appropriate tax
law specialist for consideration during a document's next scheduled
revision. 

IRS has established an ongoing dialogue with some of these
organizations and addresses many of their concerns during meetings or
through written responses.  Some of these organizations, such as the
American Institute of Certified Public Accountants, annually submit
written suggestions to IRS.  Others, such as the National Association
of Enrolled Agents, prefer to provide occasional suggestions on an
as-needed basis.  These groups sometimes hold conflicting opinions,
and IRS must balance their views along with many other factors in
making revisions.  Although no organization has all of its
suggestions implemented, most of the ones we spoke with expressed
satisfaction with IRS' accessibility and the process itself. 


   IRS EFFORTS TO IMPROVE FORMS
   AND PUBLICATIONS CONTINUE
------------------------------------------------------------ Letter :6

IRS recognizes that more efforts need to be devoted to enhancing
readability, and the agency is taking steps consistent with its
mission of improving customer service and informing and educating
taxpayers.  The agency's new Business Master Plan for 1995 through
2001 has identified maximizing customer satisfaction and reducing
taxpayer burden as one of its objectives.  One of the steps IRS plans
to take to achieve this objective is the establishment of form
simplification teams.  Comprised of IRS field personnel, these teams
will be charged with performing in-depth reviews of selected forms
and simplifying at least four each year.  This effort is to be
modelled after an earlier forms improvement project that IRS
officials considered successful.  Simplified versions of
approximately 25 high-volume forms were drafted by field personnel
during that previous project.  IRS officials expect that these new
teams will meet with similar success. 

A major effort stems from IRS' realization that taxpayers have
difficulty understanding its forms and publications, even when the
reading level of these documents is relatively low.  IRS' Compliance
Research Division is studying factors influencing taxpayer's
comprehension of tax documents.  IRS has concentrated its efforts on
how the following 10 factors affect reader comprehension: 
readability, if-then statements, references to other documents, tax
vocabulary, abbreviations and acronyms, arithmetic complexity,
headings, text, negative terminology, and graphic usage.  On the
basis of these factors, selected passages of the Form 1040 and Form
1040EZ instructions were rewritten and tested to see if comprehension
improved.  IRS is now validating its methodology for this study. 
Ultimately, IRS hopes to improve taxpayer comprehension by using the
study's findings to develop training for staff involved in writing
forms and publications. 

Another development that may improve the quality of the forms and
publications is the possible reorganization of the Tax Forms and
Publications Division.  Currently under consideration, this
reorganization would result in tax law specialists' becoming
responsible for preparing related forms and publications.  Presently,
Forms Branch staff are not involved in the development of
publications.  Similarly, Publications Branch staff do not prepare
forms.  According to IRS officials, if implemented, the
reorganization would merge staff into two new branches, one
addressing individual tax issues and the other addressing business
tax issues.  Tax law specialists would be assigned one or more forms
and accompanying publications.  IRS is considering whether such a
reorganization would make forms and publications more readable for
taxpayers by improving staff expertise and achieving greater
consistency in language between the forms and publications among
other things.  According to IRS officials, the decision on this
reorganization has been postponed pending completion of IRS' broader
internal review of its processes. 


   IRS NEEDS DATA TO BETTER
   IDENTIFY CONCERNS OF INDIVIDUAL
   TAXPAYERS
------------------------------------------------------------ Letter :7

While IRS gets information on the clarity of forms and publications
for individual taxpayers from several sources, IRS officials
acknowledge that there is not a systematic way for obtaining input
from the many individual taxpayers not represented by particular
interest groups or associations.  These officials told us that IRS
has not met with the same success in obtaining the views of
individual taxpayers as it has attained among the business community
and organizations of tax professionals, but the agency has several
efforts underway that may help to improve this situation. 

To obtain the views of individual taxpayers on such matters as the
clarity of forms and publications, IRS solicits written comments from
taxpayers, holds periodic town meetings where taxpayers can discuss
their concerns, distributes customer satisfaction surveys, and
conducts focus group sessions on selected forms revisions.  However,
IRS officials said that these sources generally do not yield many
substantive insights as to what specifically confuses individual
taxpayers.  IRS officials have told us that the concerns expressed by
individuals in these forums have not presented a precise view as to
what individuals find wrong with the forms.  According to these
officials, they also do not generally result in useful suggestions
for revising the forms.  However, the officials said that while focus
groups generally provide better results, the groups are costly to
conduct.  Because of this cost factor, only a limited number of focus
groups are held.  Also, focus groups do not cover a broad base of
taxpayers and only address one or two forms each year. 

Nonetheless, officials told us that IRS hopes to find new ways of
identifying the concerns of individuals.  In an effort to better
capture these concerns, the Publications Branch will resume its
annual interviews with the agency's telephone assistors, who respond
to questions from taxpayers on the toll-free telephone system. 
Conducted at the end of the filing season to discuss commonly asked
questions and points of confusion, these interviews were previously
used to identify and clarify passages in forms and publications for
future revisions.  Publications Branch staff claim that these
interviews yielded hundreds of specific suggestions that were
ultimately adopted.  These interviews were discontinued several years
ago due to budgetary constraints.  IRS recently decided to resume
these interviews in the spring of 1995, after the next filing season. 
This approach may be one way to tap into existing sources of
information. 

IRS plans to introduce an additional new feature to its toll-free
telephone system in January 1995.  A new line will be dedicated to
taxpayers who wish to leave recorded messages with the agency.  Also,
the annual "Message from the Commissioner," which will be included in
the 1994 tax packages, will invite taxpayers to call IRS with their
ideas for making the forms simpler.  IRS hopes these actions will
make it easier for taxpayers to comment on forms and publications and
will generate more suggestions. 

IRS may already possess critical information that could provide
insights into what areas taxpayers are specifically having difficulty
in understanding.  For example, IRS' existing toll-free telephone
system may be a source of information as to what taxpayers find
confusing.  Tracking specific questions at routine intervals may
identify specific sections of forms and publications that taxpayers
have difficulty understanding.  IRS does limited monitoring of the
nature of these calls but information captured is too broad to
provide specific guidance for form revision.  At least one state
relies on call-tracking as an indicator that certain passages in its
state tax forms are confusing and uses this information to make
appropriate changes to these documents. 

Taxpayers could also benefit from improved use of observations from
IRS employees.  One potential source of information may be errors
made by taxpayers and discovered by IRS during audits.  While some
errors are inevitable and others may be indicators of intentional
noncompliance, some frequently made errors may point to ambiguities
in forms and publications, leaving the taxpayer open to an honest
mistake. 

Another opportunity to simplify forms and publications frequently
used by individual taxpayers may reside in the agency's annual
process for proposing legislative changes to Congress.  Each year the
Department of the Treasury asks IRS to offer suggestions to improve
tax administration that need legislative approval to be implemented. 
The Treasury Department's ultimate objective is to provide Congress
with a list of such proposals for its consideration.  Simplification
of tax forms is one area of tax administration that generates
suggestions requiring legislative action.  Tax law specialists told
us that some forms contain line items or instructions required by law
but no longer serving a useful purpose.  Removing such line items and
instructions could result in some simplified forms, but only could be
accomplished by an act of Congress. 

However, this process has been perceived by some staff in various
units, including the Tax Forms and Publications Division, as not
productive.  As suggestions are forwarded to officials at
increasingly higher levels within IRS, then the Treasury Department,
and finally at OMB (which must approve the document before it is
submitted to Congress), suggested proposals are eliminated through
this process.  In recent years, few, if any, suggestions have been
forwarded to Congress.  IRS managers are presently studying ways of
revising the process to make it more useful to the Treasury
Department and Congress.  If improved, this process may encourage
greater staff participation and provide a vehicle for conveying
simplification ideas, among others, to Congress. 


   CONCLUSION
------------------------------------------------------------ Letter :8

Although it faces many challenges in developing and revising forms
and publications, IRS has instituted a process for doing so that
includes reasonable components and is seeking opportunities for
improvement.  While IRS has established a dialogue with organizations
representing tax professionals, it has had difficulty in identifying
and responding to the needs of individual taxpayers who are not
represented by any particular organization. 

Because clear and understandable forms and publications help to
promote voluntary compliance, readability is a continuous concern. 
Thus, IRS should continue to seek new ways of identifying what
individual taxpayers find most difficult to understand.  IRS should
also explore the use of potentially helpful, but untapped, sources of
information that may reveal points of taxpayer confusion and use
existing information in new ways. 


   RECOMMENDATION TO THE
   COMMISSIONER OF INTERNAL
   REVENUE
------------------------------------------------------------ Letter :9

We recommend that the Commissioner of Internal Revenue direct agency
staff to make additional efforts to identify the specific concerns of
individual taxpayers.  Identifying these concerns may be accomplished
in a variety of ways, including

  -- gathering information concerning the nature of taxpayer
     questions received through its toll-free telephone system and

  -- soliciting information from IRS field personnel including
     auditors, examiners, and customer-service representatives for
     the sole purpose of identifying common errors made by taxpayers
     that may be related to confusing passages in forms and
     publications. 


   AGENCY COMMENTS AND OUR
   EVALUATION
----------------------------------------------------------- Letter :10

We provided a draft copy of this report to, and obtained oral
comments from, appropriate IRS officials, including the Chief of
Strategic Planning and Communications and the Director of the Tax
Forms and Publications Division.  These officials suggested several
technical modifications that we incorporated in our final report. 

While they generally agreed with the facts contained in our report
and the importance of identifying the specific needs of individual
taxpayers, IRS officials did not think the recommendation we proposed
was necessary.  The officials stated that IRS is continuously seeking
the views of individual taxpayers, receiving many employee
suggestions to clarify forms and publications, and using available
data to improve these documents.  The officials noted that IRS has
additional plans to enhance customer satisfaction with regard to
forms and publications.  For example, in response to a 1993 customer
satisfaction survey, IRS intends to develop a learning, business, and
communication strategy for making forms and instructions more
readable.  While acknowledging that improvement is always possible,
the officials stated that its many current and planned efforts will
meet taxpayer needs. 

We agree that IRS has made efforts to improve its forms and
publications.  For example, IRS' efforts to identify factors
influencing taxpayers' comprehension of tax documents was a positive
step.  We also consider its future plans to dedicate a telephone line
to messages from taxpayers and to resume interviewing telephone
assistors to be positive steps.  However, we continue to support the
need for IRS to obtain more specific information about what
individual taxpayers find most confusing about forms and
publications.  We believe that implementing our recommendation will
further clarify forms and publications, thus benefitting individual
taxpayers. 


--------------------------------------------------------- Letter :10.1

We are sending copies of this report to other congressional
committees, the Secretary of the Treasury, the Commissioner of
Internal Revenue, and other interested parties. 

Major contributors to this report are listed in appendix II.  If you
or your staff have any questions concerning the report, please call
me on (202) 512-9110. 

Sincerely yours,

Lynda D.  Willis
Associate Director, Tax Policy and
 Administration Issues


ORGANIZATIONS CONTACTED
=========================================================== Appendix I

American Institute of Certified Public Accountants, Washington, D.C. 

American Payroll Association, New York

American Society of Payroll Management, New York

National Association of Enrolled Agents, Rockville, MD

National Taxpayers Union, Washington, D.C. 

Tax Executives Institute, Washington, D.C. 


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


   GENERAL GOVERNMENT DIVISION,
   WASHINGTON, D.C. 
-------------------------------------------------------- Appendix II:1

Harriet C.  Ganson, Assistant Director, Tax Policy and
 Administration Issues
Robert J.  McArter, Assistant Director, Tax Policy and
 Administration Issues
James G.  O'Donnell, Evaluator


   CHICAGO REGIONAL OFFICE
-------------------------------------------------------- Appendix II:2

Geraldine Redican-Bigott, Evaluator-in-Charge


   PHILADELPHIA REGIONAL OFFICE
-------------------------------------------------------- Appendix II:3

Linda Schmeer, Evaluator
Donald R.  White, Evaluator

*** End of document. ***