IRS' Year 2000 Efforts: Actions Are Underway to Help Ensure That
Contingency Plans Are Complete and Consistent (Letter Report, 09/14/1999,
GAO/GGD-99-176).

GAO reviewed two Internal Revenue Service (IRS) year 2000 business
continuity and contingency plans for their consistency and completeness
on the basis of IRS' guidance for such plans.

GAO noted that: (1) two IRS business continuity and contingency
plans--one for processing paper tax returns that result in a refund
(refund plan) and the other for receiving paper submissions (paper
submissions plan)--were inconsistent and incomplete in two key areas
included in IRS' guidance: (a) performance goals; and (b) mitigating
actions; (2) these weaknesses raise questions about whether these two
plans provide sufficient assurance that IRS has taken all the necessary
steps to reduce the impact of a potential year 2000 failure; (3) IRS'
guidance requires that plans specify a desirable performance goal; (4)
the performance goal for the refund plan was inconsistent with the
plan's contingency actions; (5) this inconsistency raises questions
about the goal that IRS is trying to achieve with the refund plan; (6)
the paper submissions plan did not include a performance goal; (7)
without appropriate performance goals, IRS has little assurance that the
contingency actions specified in the plan are appropriate for reducing
the impact of a potential year 2000 failure; (8) in addition, neither
plan specified the completion dates for the mitigating actions, which
IRS' guidance defines as the steps that are to be completed in advance
of a potential year 2000-related failure, to help reduce its impact; (9)
moreover, neither plan specified which individuals were to be
responsible for completing the mitigating actions; (10) IRS' guidance
requires that the plans include mitigating actions and completion dates,
but does not require that responsible individuals be identified for
completing mitigating actions; (11) however, without assigning actions
to specific individuals and identifying completion dates, IRS has little
assurance that these actions will be completed before a potential year
2000 failure; (12) in June 1999, GAO informed IRS officials of its
concerns regarding these two plans; (13) GAO also told them that its
concerns raise questions about the extent to which other plans may have
similar weaknesses; (14) in response to GAO's concerns, IRS officials
agreed to make changes to improve the completeness and consistency of
these two plans; (15) they also said they have designated an individual
that is to determine the extent to which other plans may have similar
weaknesses and revise the plans as needed; and (16) in addition, IRS
assigned one of its year 2000 contractors to set up a mechanism by which
IRS could track the implementation of business continuity and
contingency plan actions.

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

 REPORTNUM:  GGD-99-176
     TITLE:  IRS' Year 2000 Efforts: Actions Are Underway to Help
	     Ensure That Contingency Plans Are Complete and Consistent
      DATE:  09/14/1999
   SUBJECT:  Computer software verification and validation
	     Computer software
	     Systems conversions
	     Strategic information systems planning
	     Data integrity
	     Information resources management
	     Y2K
	     Tax returns
	     Tax administration systems
	     Performance measures
IDENTIFIER:  Y2K
	     IRS Service Center Automated Mail Processing System

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    United States General Accounting Office GAO               Report
    to the Commissioner of Internal Revenue September 1999    IRS'
    YEAR 2000 EFFORTS Actions Are Under Way to Help Ensure That
    Contingency Plans Are Complete and Consistent GAO/GGD-99-176
    United States General Accounting Office
    General Government Division Washington, D.C.  20548 B-283400
    September 14, 1999 The Honorable Charles O. Rossotti Commissioner
    of Internal Revenue Dear Mr. Rossotti: The Internal Revenue
    Service (IRS) agreed with recommendations we made in June 1998 to
    broaden its Year 2000-related contingency planning approach by
    developing a comprehensive, business-based set of business
    continuity and contingency plans.1 Because adequate plans are
    necessary for mitigating the impact of any Year 2000-related
    system failure, we followed up on our June 1998 report by
    reviewing two plans that address critical IRS business processes.
    We recognize that these plans are being revised to incorporate the
    results of testing that was done in July 1999. At the time we
    prepared this report, however, the testing reports were not
    completed. Because of the time-critical nature of Year 2000
    business continuity and contingency planning, we are reporting the
    results of our work at this time, rather than waiting to review
    testing reports and any revisions that may be made to the plans as
    a result of that testing. Our objective was to evaluate two IRS
    business continuity and contingency plans for their consistency
    and completeness on the basis of IRS' guidance for such plans. We
    focused on 2 of the 18 plans that IRS developed for its submission
    processing core business process. These two plans address
    processing paper tax returns that result in a refund and receiving
    paper submissions (which include tax returns).2 We reviewed these
    plans because they are designed to address failure scenarios that,
    if they occur and are prolonged, could require IRS to revert to
    manual operations for issuing refunds-something that could
    potentially affect the majority of taxpayers that file individual
    tax returns. For example, in calendar year 1998, IRS processed
    about 91 million paper individual tax 1IRS' Year 2000 Efforts:
    Business Continuity Planning Needed for Potential Year 2000 System
    Failures (GAO/GGD-98-138, June 15, 1998). 2As discussed later in
    this report, IRS identified five submission processing
    subprocesses: (1) receive paper submissions; (2) receive
    electronic submissions; (3) control and track tax and submissions;
    (4) process, correct, and forward payment data; and (5) process,
    correct, and forward tax information return data. Refund issuance
    includes aspects of several of these subprocesses. Page 1
    GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans B-283400
    returns3 and issued more than 82 million refunds totaling about
    $112 billion. Two IRS business continuity and contingency plans-
    one for processing Results in Brief    paper tax returns that
    result in a refund (hereafter referred to as the refund plan) and
    the other for receiving paper submissions (hereafter referred to
    as the paper submissions plan)-were inconsistent and incomplete in
    two key areas included in IRS' guidance: performance goals4 and
    mitigating actions. These weaknesses raise questions about whether
    these two plans provide sufficient assurance that IRS has taken
    all the necessary steps to reduce the impact of a potential Year
    2000 failure. IRS' guidance requires that plans specify a
    desirable performance goal. The performance goal for the refund
    plan was inconsistent with the plan's contingency actions. This
    inconsistency raises questions about the goal that IRS is trying
    to achieve with the refund plan. The paper submissions plan did
    not include a performance goal. Without appropriate performance
    goals, IRS has little assurance that the contingency actions
    specified in the plan are appropriate for reducing the impact of a
    potential Year 2000 failure. In addition, neither plan specified
    the completion dates for the mitigating actions, which IRS'
    guidance defines as the steps that are to be completed in advance
    of a potential Year 2000-related failure, to help reduce its
    impact. Moreover, neither plan specified which individuals were to
    be responsible for completing the mitigating actions. IRS'
    guidance requires that the plans include mitigating actions and
    completion dates, but does not require that responsible
    individuals be identified for completing mitigating actions.
    However, without assigning actions to specific individuals and
    identifying completion dates, IRS has little assurance that these
    actions will be completed before a potential Year 2000 failure. As
    part of our effort to provide IRS with timely feedback on our
    observations regarding its Year 2000 efforts, in June 1999, we
    informed IRS officials of our concerns regarding these two plans.
    We also told them that our concerns raise questions about the
    extent to which other plans may have similar weaknesses. In
    response to our concerns, IRS officials agreed to make changes to
    improve the completeness and consistency of these 3In 1998, IRS
    received more than 24 million tax returns by means other than
    paper, either electronically or via the telephone. IRS prepared
    separate business continuity and contingency plans for Year 2000
    system failures that would affect receiving electronic returns.
    4IRS' guidance refers to a performance goal as the "event
    /achievement indicating success." Page 2
    GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans B-283400
    two plans. They also said they have designated an individual that
    is to determine the extent to which other plans may have similar
    weaknesses and revise the plans as needed. In addition, IRS
    assigned one of its Year 2000 contractors to set up a mechanism by
    which IRS could track the implementation of business continuity
    and contingency plan actions. If properly implemented in a timely
    fashion, these actions will give IRS a higher level of assurance
    that its plans will help reduce the impact of a potential Year
    2000-related system failure. In light of IRS' actions, we are not
    making any recommendations at this time. Business continuity and
    contingency plans should describe the steps an Background
    organization would take to ensure the continuity of its core
    business processes in the event of a system failure. In a June
    1998 report, we made a series of recommendations5 aimed at
    broadening IRS' Year 2000 contingency planning approach to
    encompass a core business system focus as called for in our
    business continuity and contingency plan guide.6 IRS agreed with
    our recommendations and in July 1998 began to take action to
    develop a more comprehensive, business-based approach to
    contingency planning. IRS' Century Date Change Project Office7
    hired a contractor to provide business continuity and contingency
    planning expertise and training and assist the business areas in
    developing and testing their plans. IRS established a working
    group comprised of representatives from IRS' business areas to
    identify IRS' core processes and associated subprocesses. For each
    core business process, IRS established a working group to (1)
    identify possible failure scenarios for subprocesses; (2)
    determine the business impact of these failures; (3) determine
    which failure scenarios should be addressed by business
    contingency plans, based on a scoring system that included
    business impact and risk; and (4) develop plans for those
    scenarios. IRS determined that business continuity 5Specifically,
    we recommended that IRS (1) solicit the input of business
    functional area officials to identify IRS' core business processes
    and prioritize those processes that must continue in the event of
    Year 2000-induced failures, (2) map IRS' mission-critical systems
    to those core business processes, (3) determine the impact of
    information system failures on each core business process, (4)
    assess any existing business continuity and contingency plans that
    may have been developed for non-Year 2000 reasons to determine
    whether they are applicable to Year 2000-induced failures, and (5)
    develop and test contingency plans for core business processes if
    existing plans are not appropriate. See IRS' Year 2000 Efforts:
    Business Continuity Planning Needed for Potential Year 2000
    Failures (GAO/GGD-98-138, June 15, 1998). 6Year 2000 Computing
    Crisis: Business Continuity and Contingency Planning (GAO/AIMD-
    10.1.19, Aug. 1998). 7The Century Date Change Project Office
    within IRS' Information Systems organization is responsible for
    coordinating IRS' Year 2000-related activities. Page 3
    GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans B-283400
    and contingency plans should be prepared for all of the failure
    scenarios for its five submission processing subprocesses (receive
    paper submissions; receive electronic submissions; control and
    track tax and submissions; process, correct, and forward payment
    data; and process, correct, and forward tax information return
    data), several of which involve issuing refunds. In November 1998,
    IRS' Century Date Change Project Office issued its business
    continuity and contingency plan guidance8 that describes the (1)
    methodology to be used to develop business contingency plans (the
    term IRS uses for plans prepared in accordance with this guidance)
    and (2) types of information that should be included in the plans.
    IRS' guidance states that IRS used our guide to help develop its
    methodology for preparing business contingency plans. IRS' Chief
    Operations Officer designated a Year 2000 business executive to
    help coordinate the efforts of the working groups and oversee the
    development of the plans. According to IRS officials, the groups
    used IRS' guidance to develop the plans. These groups also
    received technical guidance from the contractor. Each business
    contingency plan was assigned to an executive-level official who
    was responsible for approving the plan. In the event of a Year
    2000 system-related failure, this executive is also to decide if
    and when the trigger conditions have been met for implementing the
    business contingency plan. The plans were to be tested to identify
    any needed changes. The two plans that we reviewed were tested on
    July 8 and 9, 1999, respectively.9 The refund plan and the paper
    submissions plan were inconsistent and Plans Were
    incomplete in two key areas of IRS' guidance. These areas were
    Inconsistent and    performance goals and mitigating actions.
    These weaknesses raise questions about whether these two plans
    provide sufficient assurance that Incomplete          IRS has
    taken all the necessary steps to reduce the impact of a potential
    Year 2000 failure. IRS officials agreed to make changes to these
    two plans to improve their consistency and completeness in these
    areas. In addition, IRS officials said they have taken steps to
    help ensure the consistency and completeness of other business
    contingency plans and make changes to those plans if necessary.
    8Internal Revenue Service Century Date Change Business Continuity
    and Contingency Plan, Nov. 24, 1998. 9At the time we were
    finalizing this letter, the reports showing the testing results
    were not completed. Page 4
    GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans B-283400
    IRS does not have viable, alternative backup systems for the
    various Refund Plan    information systems used for processing tax
    returns.10 Further, IRS' refund plan acknowledges that in the
    event that one or more of these systems fail, IRS may experience
    "a major work stoppage," depending on how long the failure
    continues. Given the lack of automated alternatives, the refund
    plan calls for (1) notifying the public and (2) reverting to
    manual issuance of refunds-a process that IRS currently uses for
    certain types of taxpayers (e.g., those receiving a refund of more
    than $1 million or those with a specific hardship). Although this
    business contingency plan includes a specific performance goal as
    required by IRS' guidance, that goal is inconsistent with the
    recommended contingency actions. Specifically, the plan's
    performance goal calls for issuing 20 percent of the normal refund
    volume, using a $5,000 minimum as the threshold for manual
    issuance. However, the plan's contingency procedures call for
    instituting a manual operation that would give priority to
    processing refunds for 1040EZ returns. These returns are filed by
    taxpayers with taxable incomes of less than $50,000. Consequently,
    these returns may not generate a significant number of $5,000
    refunds. The inconsistency between the performance goal and the
    business contingency plan procedures raises questions about the
    goal that IRS is trying to achieve with its contingency plan. For
    example, if IRS is trying to reduce the potential for incurring
    increased interest costs on late refunds, high-dollar refunds
    should be targeted regardless of the type of return.11 However, if
    IRS is trying to expedite tax refunds for those taxpayers who may
    have the greatest financial need, a performance goal that focuses
    on issuing refunds of $5,000 or more may not be appropriate. In
    our June 1999 meeting with IRS officials, we pointed out this
    inconsistency, and they agreed that they needed to change the
    plan's performance goal. In our meeting, the executive that was
    responsible for this plan said the plan's performance goal should
    focus on issuing refunds to certain "hardship" taxpayers.
    According to IRS, hardship taxpayers 10This plan addresses the
    business processes that would be implemented if one or more of the
    following systems fail: (1) Generalized Unpostable Framework, (2)
    Service Center Control File, (3) Generalized Mainline Framework,
    (4) Error Resolution System, and (5) Multiple Virtual Storage
    Enterprise System Architecture (MVSEA). This plan does not address
    business processes that fall under the purview of the Department
    of the Treasury's Financial Management Service, which is
    responsible for, among other things, receiving and processing
    requests for issuance of IRS refund checks. 11As stated in section
    6611(e) of the Internal Revenue Code, IRS has until 45 days from
    the receipt of the tax return or the due date of the return,
    whichever is later, to issue a refund. If IRS fails to meet that
    time frame, the taxpayer is entitled to interest on his or her
    refund amount. Page 5
    GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans B-283400
    would be those that filed a return with (1) a Form 911,
    Application for Taxpayer Assistance Order; (2) an earned income
    tax credit, which is a refundable tax credit available to low-
    income, working taxpayers; or (3) an adjusted gross income within
    a certain dollar range that is to be determined if a Year 2000
    failure actually occurs. With respect to mitigating actions, this
    plan did not include dates for completing them before a potential
    Year 2000 failure. Examples of the plan's mitigating actions
    include (1) preparing a letter to the Department of the Treasury's
    Financial Management Service outlining the process for
    transferring refund documents and files, (2) planning for one
    additional week of training on the manual refund issuance process,
    (3) identifying additional secure storage space in each service
    center, and (4) coordinating press release information with IRS'
    Office of Public Affairs. Moreover, the plan did not specify which
    individuals were to be responsible for completing the mitigating
    actions. Although IRS' guidance does not require that the plan
    identify specific individuals, without identifying responsible
    individuals and dates for completing the mitigating actions, IRS
    has little assurance that these actions will be completed before a
    potential Year 2000 failure. In our June 1999 meeting, the
    executive responsible for this plan acknowledged this omission and
    agreed that the mitigating actions should identify responsible
    individuals and completion dates. IRS receives paper submissions,
    including tax returns, at each service Paper Submissions Plan
    center loading dock. From the loading dock, the returns are taken
    to the mailroom for sorting. IRS' Service Center Automated Mail
    Processing System (SCAMPS) is a new automated system that IRS uses
    to sort the mail. SCAMPS is to (1) open the envelopes to expedite
    the extraction process, in which employees remove the tax return
    information from the envelopes; (2) identify those tax returns
    with checks; (3) read the bar- coded tax return envelopes and sort
    them into one of 40 different categories; and (4) sort outgoing
    mail. The paper submissions plan focuses on the contingency
    actions to be implemented in the event that SCAMPS experiences a
    Year 2000 system failure. Although IRS' guidance calls for plans
    to contain a performance goal, the paper submissions plan did not
    include one. According to the plan, "specific performance measures
    for manual mail handling operations are not yet available."
    However, without a performance goal, it is unclear how IRS
    determined that it would be sufficient to "use available service
    center personnel to handle incoming mail" as specified in the
    plan. Page 6                    GAO/GGD-99-176 IRS' Year 2000
    Business Contingency Plans B-283400 While we recognize that IRS is
    developing new performance measures that may not yet be available
    for this business function, in our June 1999 meeting with IRS
    officials, we identified information that could be used to develop
    a performance goal for the plan. For example, the SCAMPS
    processing rate could be used as a guide for developing an
    acceptable (albeit reduced) level of service for a manual mail
    sorting process. IRS could also use its productivity data on
    employees that manually extract tax return information from
    envelopes as a basis for developing a performance goal. The IRS
    executive that was responsible for this plan agreed that a goal
    should be included and that these two data sources could be used
    to develop that goal. The plan's mitigating actions were also
    incomplete. Like the refund plan, this plan did not include the
    dates and the responsible individuals for completing the plan's
    two mitigating actions. Also, we told IRS officials that we had
    questions about the viability of one of the plan's mitigating
    actions. That action calls for reverting back to a mail sorting
    system that is currently not Year 2000 compliant. Even if IRS
    could develop a workaround solution to make the older mail sorting
    system Year 2000 compliant, IRS officials said that they had
    planned to remove the equipment for the older system by the 2000
    filing season. IRS officials told us that as a result of testing
    this plan, this mitigating action would be deleted in the revised
    plan. The executive responsible for this plan also agreed to add
    responsible individuals and the dates for completing the other
    mitigating action, which pertains to sorting outgoing mail. In
    addition to agreeing to make changes to the two plans, IRS
    officials said Actions Are Under Way to    that actions are under
    way to help ensure that other business contingency Help Ensure
    Consistency     plans are consistent and complete. According to
    officials in IRS' Business and Completeness of All     Systems
    Requirements Office (BSRO),12 a staff member has been Plans
    designated to review all of the business contingency plans for
    consistency and completeness and for crosscutting issues among the
    plans. Heretofore, BSRO did not view this as its function, in part
    because according to BSRO officials, it had a limited number of
    staff. IRS also has issued a work request for one of its Year 2000
    contractors to develop a database that BSRO staff could use to
    track the implementation of key elements of the business
    contingency plan (e.g., triggers, mitigating actions, contingency
    team actions). According to IRS, information from the business
    contingency plans is to be added to the database by late September
    1999, and reports are to be generated shortly thereafter. 12BSRO,
    among other things, provides support to business functions for
    contingency planning and helps ensure Year 2000 compliance for the
    Chief Operations Officer organizations. Page 7
    GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans B-283400
    If properly implemented in a timely fashion, these actions should
    provide IRS with a higher level of assurance that its business
    contingency plans will help reduce the impact in the event of a
    Year 2000related system failure. Accordingly, we are not making
    any recommendations at this time. To achieve our objective of
    evaluating the consistency and completeness Scope and        of
    two of IRS' Year 2000 business contingency plans according to IRS'
    Methodology      guidance, we *  reviewed the following business
    continuity and contingency plan guidance: (1) Year 2000 Computing
    Crisis: Business Continuity and Contingency Planning (GAO/AIMD-
    10.1.19, Aug. 1998); (2) Internal Revenue Service Century Date
    Change Contingency Management Plan, (Version 5.0, Mar. 1, 1999);
    and (3) Internal Revenue Service Century Date Change Business
    Continuity and Contingency Plan, (Version 1.0, Nov. 24, 1998); *
    interviewed officials from the Century Date Change Project Office;
*  interviewed members of the submission processing contingency
    plan working group, the executive that was responsible for the two
    plans we reviewed, the Business Year 2000 Executive, and other
    BSRO staff; *  toured the Atlanta Service Center to learn more
    about how tax returns are processed through IRS' information
    systems; and *  reviewed 6 of the 10 sections of the two business
    contingency plans to determine whether they were consistent with
    IRS' guidance. We did not analyze four sections of the plans
    (training and testing, post- event wrap-up, contingency actions
    log sheet, and information recovery) for several reasons. In lieu
    of including the testing procedures in the plan, IRS developed
    separate test plans for each contingency plan. To provide timely
    feedback to IRS so that they could begin corrective actions
    promptly, we focused our efforts on the business contingency plans
    themselves rather than the test plans. We did not analyze the
    post-event wrap-up information or the contingency actions log
    sheet because these sections are to be completed after the
    business contingency plan has been implemented. Both plans
    included little information about information recovery (i.e.,
    regaining or retrieving data that may be lost or damaged as a
    result of a system failure).13 13The refund plan stated that (1)
    lost data could be recovered from original documents given that
    returns are stored up to 6 months at the service centers, and (2)
    recovery of damaged data was under the purview of IRS' Information
    Systems contingency plans. We did not review these plans. The
    paper submissions plan indicated that developing manual procedures
    for recovering the types of management information data generated
    by SCAMPS was not possible. Page 8
    GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans B-283400
    We also did not review any existing business resumption plans that
    IRS developed for other than Year 2000-induced failures, and we
    did not examine the relationship between individual Year 2000
    business contingency plans and IRS' "End Game" activities,14 which
    IRS is currently developing. We conducted our review from May 1999
    to July 1999 in accordance with generally accepted government
    auditing standards. On August 27, 1999, we obtained written
    comments on a draft of this Agency Comments and report from the
    Commissioner of Internal Revenue. (See app. I for a copy Our
    Evaluation                 of IRS' letter.) IRS said that it
    generally agreed with the issues raised in our report and is
    taking the necessary steps to correct them. IRS also amplified on
    its business contingency plan testing process and clarified some
    facts and provided updated information, which we included in the
    report where appropriate. IRS said that it had envisioned that the
    business contingency plans were "living documents" that would be
    revised over time to reflect changes in technology, business
    processes, and legislation. Furthermore, IRS said that the plans
    were to be tested by subject matter experts, including field
    staff, to ensure their viability, which would result in
    modifications to the plans. We agree that the plans were to be
    living documents and designed our methodology accordingly.
    Recognizing that the plans were subject to change based on the
    results of business contingency plan testing (as stated on p. 1 of
    our draft report), we met with IRS in June 1999 to discuss our
    initial findings. We scheduled this meeting, in part, so that IRS
    would have the benefit of our feedback while the plans were still
    subject to change, and possibly before they were to be tested. IRS
    said that as a result of our findings on the weaknesses in the
    plans and the results of testing two plans, it has begun work to
    address our concerns. We are sending copies of this letter to
    Representative Amo Houghton, Chairman, and Representative William
    J. Coyne, Ranking Minority Member, Subcommittee on Oversight,
    House Committee on Ways and Means; Senator Robert F. Bennett,
    Chairman, and Senator Christopher J. Dodd, Vice-Chairman, Senate
    Special Committee on the Year 2000 Technology Problem; and
    Representative Stephen Horn, Chairman, and 14IRS has a three-part
    "End Game" strategy that involves (1) preparing back-up data
    during the New Year's weekend; (2) conducting validation checks of
    its systems, telecommunications, and facilities during the New
    Year's weekend to identify any issues before the first day of
    business in 2000; and (3) proactively monitoring key events to
    mitigate Year 2000-related problems that may interrupt national
    tax processing. IRS' monitoring efforts are scheduled to continue
    through March 2000. Page 9
    GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans B-283400
    Representative Jim Turner, Ranking Minority Member, Subcommittee
    on Government Management, Information and Technology, House
    Committee on Government Reform. We are also sending copies to the
    Honorable Lawrence H. Summers, Secretary of the Treasury, and the
    Honorable Jacob J. Lew, Director of the Office of Management and
    Budget. Copies will be made available to others on request. If you
    have any questions about the information contained in this report,
    please contact me or Sherrie Russ at (202) 512-9110. Key
    contributors to this assignment were Jackie Nowicki, Joanna
    Stamatiades, and Linda Standau. Sincerely yours, James R. White
    Director, Tax Policy and Administration Issues Page 10
    GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans Page 11
    GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans Appendix
    I Comments From the Internal Revenue Service Page 12    GAO/GGD-
    99-176 IRS' Year 2000 Business Contingency Plans Appendix I
    Comments From the Internal Revenue Service Page 13
    GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans Appendix
    I Comments From the Internal Revenue Service Page 14
    GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans Page 15
    GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans Page 16
    GAO/GGD-99-176 IRS' Year 2000 Business Contingency Plans Ordering
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