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Title:
GAO legislation agency comments and other related materials on S. 2352 ... H.R. 8948 ...
Physical Description:
v, 35 p. : ; 24 cm.
Language:
English
Creator:
United States -- Congress. -- Senate. -- Committee on Government Operations
Publisher:
U.S. Govt. Print. Off.
Place of Publication:
Washington
Publication Date:

Subjects

Subjects / Keywords:
Legislative auditing -- United States   ( lcsh )
Genre:
federal government publication   ( marcgt )
non-fiction   ( marcgt )

Notes

General Note:
At head of title: 94th Congress, 2d session. Committee print.
Statement of Responsibility:
prepared by the Committee on Government Operations, United States Senate, March 30, 1976.

Record Information

Source Institution:
University of Florida
Rights Management:
All applicable rights reserved by the source institution and holding location.
Resource Identifier:
aleph - 025785827
oclc - 02526595
lccn - 76601761
System ID:
AA00022554:00001

Table of Contents
    Front Cover
        Page i
        Page ii
    Preface
        Page iii
        Page iv
    Table of Contents
        Page v
        Page vi
    Main body
        Page 1
        Page 2
        Page 3
        Page 4
        Page 5
        Page 6
        Page 7
        Page 8
        Page 9
        Page 10
        Page 11
        Page 12
        Page 13
        Page 14
        Page 15
        Page 16
        Page 17
        Page 18
        Page 19
        Page 20
        Page 21
        Page 22
        Page 23
        Page 24
        Page 25
        Page 26
        Page 27
        Page 28
        Page 29
        Page 30
        Page 31
        Page 32
        Page 33
        Page 34
        Page 35
        Page 36
    Back Cover
        Page 37
        Page 38
Full Text



94th Congress }
2d Session


COMMITTEE PRINT


GAO LEGISL


~UA ~



~


AGENCY COTMTMEN-TS AN, 3!TJERI
RELATED MATERJIAL:S-f&

ON

S. 2352
TO AMEND THE ACCOUNTING AND AUDITING ACT OF 1950
TO PROVIDE FOR THE AUDIT, BY THE COMPTROLLER GEN-
ERAL, OF THE INTERNAL REVENUE SERVICE AND OF THE
BUREAU OF ALCOHOL, TOBACCO, AND FIREARMS

H.R. 8948
TO AMEND THE ACCOUNTING AND AUDITING ACT OF 1950
TO PROVIDE FOR THE AUDIT, BY THE COMPTROLLER GEN-
ERAL, OF THE INTERNAL REVENUE SERVICE AND OF THE
BUREAU OF ALCOHOL, TOBACCO, AND FIREARMS





PREPARED BY THE

COMMITTEE ON GOVERNMENT OPERATIONS

UNITED STATES SENATE


MARCH 30, 1976


Printed for the use of the Committee on Government Operations


U.S. GOVERNMENT PRINTING OFFICE


WASHINGTON : 1976


I


I


68-625 O













COMMITTEE ON GOVERNMENT OPERATIONS


ABRAHAM RIBICOFF, Connecticut, Chairman
JOHN L. McCLELLAN, Arkansas CHARLES H. PERCY, Illinois
HENRY M. JACKSON, Washington JACOB K. JAVITS, New York
EDMUND S. MUSKIE, Maine WILLIAM V. ROTH, JR., Delaware
LEE METCALF, Montana BILL BROCK, Tennessee
JAMES B. ALLEN, Alabama LOWELL P. WEICKER, JR., Connecticut
LAWTON CHILES, Florida
SAM NUNN, Georgia
JOHN GLENN, Ohio


RICHARD A. WEGMAN, Chief Counsel and Staff Director
PAUL HOFF, Counsel
PAUL L. LEVENTHAL, Counsel
ELI E. NOBLEMAN, Counsel
DAVID R. SCHAEFER, Counsel
MATTHEW SCHNEIDER, Counsel
JOHN B. CHILDERS, Chief Counsel to the Minority
BRIAN CONBOY, Special Counsel to the Minority
MARILYN A. HARRIS, Chief Clerk
ELIZABETH A. PREAST, Assistant Chief Clerk
HAROLD C. ANDERSON, Staff Editor



SUBCOMMITTEE ON REPORTS, ACCOUNTING AND MANAGEMENT
LEE METCALF, Montana, Chairman


JOHN L. McCLELLAN, Arkansas
EDMUND S. MUSKIE, Maine
SAM NUNN, Georgia
JOHN GLENN, Ohio


BILL BROCK, Tennessee
CHARLES H. PERCY, Illinois
LOWELL P. WEICKER, JR., Connecticut


VIC REINEMER, Staff Director
E. WINSLOW TURNER, Chief Counsel
LYLE RYTER, Minority Counsel
JACK CHESSON, Counsel
GERALD STURGES, Professional Staff Member
JEANNE A. MCNAUGHTON, Chief Clerk


(II)













PREFACE


In October of 1975, the Subcommittee on Reports, Accounting, and
Management held hearings on a number of pieces of legislation in-
volving the General Accounting Office, including S. 2352, a bill to
provide for the audit by the Comptroller General, of the Internal
Revenue Service and of the Bureau of Alcohol, Tobacco and Firearms.
The hearing record printed by the Subcommittee provides a complete
compilation of testimony and supporting materials with respect to
this legislation.
Prior to Subcommittee action on S. 2352, the House of Representa-
tives passed an amended version of H.R. 8948, a bill almost identical
to S. 2352. H.R. 8948 was referred to the Subcommittee on Reports.
Accounting, and Management for consideration. In December of 1975
the Subcommittee decided to discharge H.R. 8948 to the full Commit-
tee for final action in lieu of reporting out S. 2352.
Subsequent to the printing of Part 1 of the Subcommittee's hearings
on GAO legislation, a number of comments and materials have been
received by the Subcommittee and the full Government Operations
Committee which materials were utilized by the Committee in the
course of its deliberations on H.R. 8948 and the amendments the Coin-
mittee adopted thereto. This Committee print contains those materials.


(III)


















Digitized by the Internet Archive


n 2013


http://archive.org/details/gaolegOu nit












CONTENTS

Page
Text of S. 2352, a bill to amend the Accounting and Auditing Act of 1950
to provide for the audit, by the Comptroller General, of the Internal
Revenue Service and of the Bureau of Alcohol, Tobacco and Firearms- 1
Text of H.R. 8948, an Act to amend the Accounting and Auditing Act of
1950 to provide for the audit, by the Comptroller General, of the Internal
Revenue Service and of the Bureau of Alchool, Tobacco and Firearms;
as passed by the House of Representatives on October 20, 1975 -------- 4
GAO Draft Procedure for Safeguarding of Tax Returns and Tax Return
Information Obtained by Designated Representatives of the General
Accounting Office for Purposes of Evaluating Administration of the
Internal Revenue Laws ------------------------------------------- 7
Report from the Library of Congress, Congressional Research Service,
entitled: "Authorized Recipients of Income fax Returns from the IRS"- 11
Letter from Richard R. Albrecht, General Counsel of the Treasury, to
Chairman Ribicoff, December 9, 1975 -------------------------------15
Text of letter from the staff of the Committee on Government Operations
to Meade Whitaker, Chief Counsel, Internal Revenue Service; Irvine
Crawford, Associate Director, General Government Division, General
Accounting Office; and Hershel F. Clesner, Chief Counsel, Commerce,
Consumer and Monetary Affairs Subcommittee of the House Committee
on Government Operations, December 31, 1975 ------------------- 17
Letter from Meade Whitaker, Chief Counsel, Internal Revenue Service
to the staff of the Committee on Government Operations, January 9,
1976 ----------------------------------------------------------- 21
Letter from Herschel F. Clesner, Chief Counsel, Commerce, Consumer
and Monetary Affairs Subcommittee of the House Committee on
Government Operations to the staff of the Committee on Government
Operations, January 13, 1976 --------------------------------------25
Letter from Milton J. Socolar, Deputy General Counsel, General Account-
ing Office, to the staff of the Committee on Government Operations,
January 16, 1976 ------------------------------------------------- 27
Letter from Hope Eastman, Associate Director, American Civil Liberties
Union, to the staff of the Committee on Government Operations, Janu-
ary 7, 1976 ------------------------------------------------------ 29
Reports from the General Accounting Office:
Reports Issued by the General Accounting Office on Activities of the
Internal Revenue Service and the Bureau of Alcohol, Tobacco and
Firearms for the period January 1971 through January 1976 ------- 32
Work in process by the General Accounting Office for the Joint
Committee on Internal Revenue Taxation as of March 1976 ------ 34
Work in process by the General Accounting Office undertaken under
its own authority as of March 1976 -----------------------------35









94T1S CONGRESS
CONGRESS S. 2352




IN THE SENATE OF THE UNITED STATES
SEPTEM3BER 17 (1ei isiat ive day. SEPTEiMBER 11), 1915
Mr. METCALF introduced the followin- bill, which was read twice and referred
to the Committee on Government O1,erations




A BILL
To amend the Accounting and Auditing Act of 1950 to provide
for the audit, by the Comptroller General. of the Internal
Revenue Service and of the Bureau of Alcohol, Tolacco, and
Firearms.

1 Be it enacted by the Senate mid House of Represeuta-

2 ties of the United States of America in Congress assembled,
3 That section 117 of the Accounting and Auditing Act of

4 1950 (31 U.S.C. 67) is amended by adding at the end

5 thereof the following new subsection:

6 (d) (1) The Comptroller General shall make, uiinde

7 such rules and regulations as he shall prescribe, audits of the

8 Internal Revenue Service and the Bureau of Alcohol,

9 Tobacco, and Firearms of the Department of the Treasury"
II (1)










i P',,1(l 4. Thai Iwh a tidit, ilall wt affect tile finality of
., t~ml~ iii ridtt o ( d- Scrtiarv of thel ury or his
.1, --l itc' tlinder cctioiil (,4(1; 1)1f fte hllerlal ] WNveliue (1c .

2) or p.rl.wII t ,. aId I' II to I xtcit t ( l- csa ry in,

5 illa!..in l lltc all(lls utql'(t d I ,x w' rilgiTph (1) of this sub-

; Ii, Vt rel~rt~v i t, I f4 thie Gi cilwal Ac clilliting Office-

(" .\) 'hall 1 \t i twlthILandit r thl e provisions of see-

t (i,, 4424 and (M14)1 Of Sudth ('odV, have access to tOx

1 rct l [ and ta rclur if nIilln describe ed in sections

"10 442- (a) and 610:1; and

it (B1) Shall have acces-' to all ther books, accounts,

12 fii t'a Ii;I1 re- 4l'dS. retl.pfl' ,h paprs, things, and prop-
1: elv ,lc b ngr to or ill us'c 1)v the IIterlull Revenue Serv-

t itt (r I. ie Blirteu of Alcohol, io(lctco, and Firearms:

15 Pr 4.wiI, That ito officer or employee of the General Ae-
I hi (111 uitg (A()ihe duaill. txpt to tile extent authorized by see-

1 tii (;1(,) (d) of suih (ode, divulge or make known in any

iS lii itie ,vlia ever to aiiv person, other than another officer
1 ,r ti nlp,,vt of ';iith office whose oftic41l dutis or responsi-

2) Jiliti(', F lTIr Mt'- h di.-' t'l re, any tax return or tax return
'Il! infiiwition (lscrilwl in seetion 4424 (a) of sutch Code in a

*2 I ,' )I l\ ii Wi can Ie is ciatd xi li or otherwisee identify

2;:; dir Iv ,r inl(lil -tly, a pl rticular taxpayer" I Al proi( (I

2 /Il T Ii 1w)a ll ti.r tx(. ea libl, ee ,t the (Wie era'l l Account-
_". Cig{tii lal x(eI't as othenvx'i. e, expressly provided by3






3
1 law, divulge or maie known in any winner whatever to ally

2 person, other than another officer or employee of such office

3 whose official duties or responsibilities require such disclosure,
4 any other tax return or tax return iiforma tion, or any infor-

5 mation described in clause (B) in a form which can be
6 associated with or otherwise identify, directly or indirectly,

7 a particular taxpayer. Any such officer or employee who
8 makes a disclosure in violation of either of the foregoing

9 provisos shall be subject to the penalties provided by law.
10 "(3) The Comptroller General shall, as frequently as
11 may be practicable, make reports to the Congress on the

12 results of audit work performed.".


68-625 0 76 2








94T1 CONGRESS
DH. R. 8948




IN TIEI -sEi-NATE OF TILE VNITI) STATES
()r(rT I~ H 1, 19, .,
Rea( t wWe and referred to the Committee on (overunelit Operations




AN ACT
To mnend the Accounting and Auditing Act of 1950 to provide
for the audit, by the (omptroller General, of the Internal
Revenue Service and of the Bureau of Alcohol, Tobacco,
and Firearms.

1 Be it enacted by the Seniate and House of Representa-
2 t res of the Unitad States of America in Congress assembled,
3 That section 117 of the Accounting and Auditing Act of

4 1950 (31 [ .S.(. 67) is amended by adding at the end

5 thereof the following new subsection

6 (d) (1) The Comptroller General shall make, under

7 such rules and regulations as he shall prescribe, audits of
8 the Internal Revenue Service and the Bureau of Alcohol,

9 Tobacco, and Firearms of the Department of the Treasury:
II











1 Provided, That such audits shall not affect the finality of

2 findings or decisions of the Secretary of the Treasury or his
3 delegate under section 6406 of the Internal Revenue Code.
4 (2) For purposes of, and to the extent necessary in,

5 making the audits required by paragraph (1) of this sub-

6 section, representatives of the General Accounting Office-
7 (A) shall, notwithstanding the provisions of see-

8 tions 4424 and 6103 of such Code, have access to tax
9 returns and tax return information described in sections

10 4424 (a) and 6103; and
11 (B) shall have access to all other books, accounts,

12 financial records, reports, files, papers, things, and prop-

13 erty belonging to or in use by the Internal Revenue
14 Service or the Bureau of Alcohol, Tobacco, and Fire-

15 arms:

16 Provided, That no officer or employee of the General Ac-

17 counting Office shall, except to the extent authorized by sec-

18 tion 6103 (d) of such Code, divulge or make known in any

19 manner whatever to any person, other than another officer or

20 employee of such office whose official duties or responsibilities

21 require such disclosure, any tax return or tax return infor-

22 mation described in section 4424 (a) of such Code in a form
23 whioh can be associated with or otherwise identify, directly

24 or indirectly, a particular taxpayer: And provided further.,

25 That no officer or employee of the General Accounting Office








3
1 sull, except as otherwise expressly providdlA by Iaw, divulge

2 or make known in any manner what-ver to any person, other
3 than another officer or eniployee of such office whose official

4 duties or response cities require suoh disclosure, any otl r

5 tax return or tax return information, or any information

6 described in clause (B) in a forim which can be asoc-ited
7 with or otherwise identify, directly or indirectly, i particular

8 taxpayer. Any such officer or employee who makes a dis-
9 closure in violation of either of the foregoing provi.os shall

10 be subject to the penalties provided by law.

11 "(3) The Comptroller General shall, as frequently as

12 may be practicable, make reports to the Congress on the

13 results of audit work performed.".
IPassed the House of Representatives October 20, 1975.

Attest: W. PAT JENNINGS,
Clerk.













PROCEDURE FOR SAFEGUARDING OF TAX RETURNS
AND TAX RETURN INFOP.'ATION; OBTAINED BY
DESIGNATED REPRESE!TATIVES OF THE GENERAL
ACCOUNTING.OFFFCE FOR PURPOSES OF EVALUATING
ADMINISTRATION OF THE INTERNAL REVENUE LAWS


I -- Purpose and Scope

1. Reference throughout these procedures t the safeguarding of tax

returns and tax return information means the safeguarding of information

so as to preclude disclosure in any form which would enable association

with or identification of a particular taxpayer.

2. These instructions establish minimum standards governing the

transmission, custody, and disclosure of tax returns and tax return

information, consistent with the provisions of sections 4424 and 6103 of

the Internal Revenue Code.

3. Nothing in these regulations shall be construed as authorizing

disclosure, dissemination, release, handling, or transmission of tax

returns and tax return information contrary to the specific provisions

of any law.

4. The policies and procedures herein established are designed to

preclude the unauthorized disclosure of tax returns and tax return infor-

mation coming into the custody of the General Accounting Office or its

employees.

II -- Individual Responsibility

5. The effectiveness of this tax return and tax return information

security program depends upon the alertness, reliability, and discretion

of every individual who receives tax returns and tax return information.













The importance of effective security and of the position of trust imposed

upon each individual who has possession, access, or control of such

information is indicated by the criminal penalties imposed by 18 U.S.C

1905 and 26 U.S.C. 7213.

III -- Access to and Dissemination and
Control of Tax Returns and Tax Information

6. The following principles and requirements will be adhered to in

the General Accounting Office:

a. Access to tax returns and tax return information shall be

limited to those employees of the General Accounting Office designated

by the Comptroller General or his designee as having a need for such

returns and information in connection with the carrying out of their

official duties. No person shall be entitled to knowledge or possession

of, or access to, tax returns and tax return information solely by virtue

of his office or position.

b. Tax returns and tax return information shall not be

disseminated to or discussed with or in the presence of unauthorized

persons.

c. Any person who has knowledge of the loss or possible

compromise of any tax return or tax return information shall promptly

report the circumstances to the Comptroller General or his designee who

shall take appropriate action forthwith, including advice to the Internal

Revenue Service or the Bureau of Alcohol, Tobacco and Firearms, as the

case may be.


-2-












IV -- Physical Control Over Tax
Returns and Tax Information

7. Representatives of the General Accounting Office designated by

the Comptroller General or his designee shall be responsible for main-

taining, as a minimum, control over tax returns and tax return information

consistent with security requirements maintained by the Internal Revenue

Service and the Bureau of Alcohol, Tobacco and Firearms.

8. Transmittal of tax returns and tax return information and

related working papers which are transferred between offices of the

General Accounting Office shall be by registered mail with a return

receipt to be signed by a designated representative who is authorized

access to tax returns and tax return information.

9. Tax returns and tax return information and related working papers

shall be stored under the sole control of designated employees who are

authorized access to tax returns and tax return information. When copies

of tax returns and tax return information and related working papers are

no longer needed, they shall be destroyed under the supervision of a

designated representative who is authorized access to tax returns and tax

return information.

The General Accounting Office shall not retain custody of original

tax returns except by special arrangement made with the Commissioner of

Internal Reven,'e Service or his designee.


-3-






10







V -- General

I0. The Comptroller General or his designee will cooperate with

the Coilissioner of Internal Revenue in implementing any additional

control or safeg9uard deeed necessary to provide security of tax returns

and tax return information in the possession of the General Accounting

Office.


-4-







11




THE LIBRARY OF CONGRESS)

Congressional Research Service
/I s


WASHINGTON, D.C. 20540
February 24, 1976

To: Senate Government Operations Committee
Attention: David Schaeffer

From: American Law Division

Subject: Authorized Recipients of Income Tax Returns from the IRS


This memorandum is pursuant to your inquiry of February 23,

1976, requesting a listing of those individuals or agencies authorized

to receive tax returns from the Internal Revenue Service. The basic

statutory authorization is by Section 6103 of the Internal Revenue

Code of 1954, as amended (hereinafter, Section 6103). This has been

interpreted by the regulations thereunder and expanded by certain ex-

ecutive orders. The following listing contains those agencies and

individuals authorized to receive tax returns. The authority is desig-

nated by each listing:

1. State officers. Section 6103(b);
2. State bodies and commissions. Section 6103(b)(2);
3. Bona fide shareholders of record owning at least 1 per-
cent of the outstanding stock of a corporation may examine
corporate returns. Section 6103(c);
4. The House Committee on Ways and Means and the Senate
Finance Committees, and the Joint Committee on Internal
Revenue Taxation. Section 6103(d);
5. Any committee of Congress, select in nature, specific-
ally authorized by resolution of Congress to receive tax
returns. Section 6103(d);
6. Department of Labor and Pension Benefit Guaranty Cor-
poration for administration of Employee Retirement Income
Security Act of 19714. Section 6103(g);
7. Secretary of Health, Education and Welfare, for carrying
out section 232 of the Social Security Act. Section 6103(h);


68-625 0 76 3







12


C-2



FY individual making the return. Treas. Reg. Sec. 301.

L. The trustee, cormittee or guardian of the estate of the
individual making the return if he or she is incompetent.
Tres R~.Sc !13a-~ ii)(b);
l0. Adrinistrator, executor, or trustee of the individual
nakinj th return's estate, if the individual has died,
or, in th dis.cretion of the Secretary of the Treasury,
any heir at law or next of kin, beneficiary under the
sill. Treas. Reg. Sec. 301.6103(a)-l(c)(ii)(c);
11. Receiver or trustee in bankruptcy of an individual
making the return where such individual has filed in
bankruptcy. Treas. Reg. Sec. 301.6103(a)-l'c)(ii)(d);
12. Attorney in fact of any of the other individuals noted
in Treas. Reg. Sec. 301.6103(a)-l(c)(ii);
13. Other individual making a joint return with the tax-
payer. Treas. Reg. Sec. 301.6103(a)-l(c)(iii)(a);
(also note, the same rules as 8-12 apply for joint returns)
14. Any partner may see the partnership return. Treas.
Reg. Sec. 301.6103(a)-1(c)(l)(iv)(a);
15. Guardian, trustee or committee of a partner may see the
partnership return where such partner is incompetent. Treas.
Reg. Sec. 301.6103(a)-l(c)(1)(iv)(b );
16. Administrator, executor or trustee of the estate of
a deceased partner or, in the Secretary's discretion, an
heir, beneficiary under the will or next of kin may see
the tax return of the partnership. Treas. Reg. Sec. 301.
6103(a)-l(c)(l)(iv)(c);
17. Trustee or receiver in bankruptcy If the partnership
is in bankruptcy may see the return of the partnership.
Treas. Reg. Sec. 301.6103(a)-l(c)(1)(iv)(d);
18. Attorney in fact for anyone noted in 14-17 may see
the partnership return. Treas. Reg. Sec. 301.6103(a)-1(c)
(1)(iv)(e) ;
19. The administrator, executor or trustee of an estate
may see the estate's income tax return. Treas. Reg. Sec.
301.6103(a)-i(c)(l)(v)(a);
20. In the Secretary's discretion, any heir at law, next
of kin or beneficiary may see the estate's income tax
return. Treas. Reg. Sec. 301.r6lO3(a)-l(c)(1)(v)(b);
21. The attorney in fact for 19 or 20 may see the estate's
income tax return. Treas. i~eg. Sec. 301.C103(a)-l(C)(1)(v)(c);
22. The tristees may see a trust's return. Treas. Reg. Sec.
301.6103(a)-l(c)(1)(vi)(a);
23. Beneficiaries of a trust, or the beneficiary's legal
guardian or committee if incompetent may see the trust's







13







r,:urn. Trieas;. So. 01.01O(a)-l()(1)(vi)(b), <);
24. The administrator, executor or trustee of the estate
of a deceased oeneficiary or, in the Secretary's discre-
tion, heirs, beneficiaries or next of kin of the deceased
trust beneficiary may see the trust's income tax return.
Treas. Reg. Sec. 3Oi. 103 ,a)-l(c)(i)(vi)(d);
25. Attorney in fact for 22-24 may see the trust return.
Treas. Reg. Sec. 301.6103(a)-l(c)(1)(vi)(e):
26. Designatee of the board of directors, officer or employee
under written request of the principal officer and secretary
and attorney in fact of a corporation may see the corporate
tax returns. Treas. Reg. Sec. 301.6103(a)-l(c)(1)(vii)(a),
(b), (c);
27. The receiver or trustee in bankruptcy may see a corpor-
ation's return. Treas. Reg. Sec. 301.6103(a)-l(c)(1)(vii)
(d);
2,9. The District of Columbia, the Commonwealth of Puerto
Rico and U.S. possessions may inspect tax returns.
Treas. Beg. Sec. 301.6103(a)-l(d);
29. The officers and employees of the Department of the
Treasury. Treas. Reg. Sec. 01.6103(a)-l(e);
30. Upon application in writing by the head of ax execu-
tive department or establishment of the Federal Govern-
ment to the Secretary of the Treasury or the Commissioner
of Internal Revenue, such agencies may receive tax returns.
Treas. Reg. Sec. 301.6103(a)-l(f);
31. Attorneys of the Department of Justice and United
States Attorneys may receive tax returns. Treas. Reg. Sec.
301.6103(a)-l(g);
32. Department of Health, Education and Welfare for
administration of Title II of the Social Security Act.
Treas. Reg. Sec. 301.6103(a)-100;
33. Securities and Exchange Commission may receive corporate
income tax returns. Treas. Reg. Sec. 301.6103(a)-102;
34. Advisory Commission on Intergovernmental Relations.
Treas. Reg. Sec. 301.6103(a)-103;
35. Department of Commerce. Treas. Reg. Sec. 301.6103(a)-
104;
36. Renegotiation Board may inspect returns. Treas. Reg.
Sec. 301.6103(a)-105;
37. Federal Trade Commission may inspec't returns. Treas.
Reg. Sec. 301.6103(a)-106;
38. Various committees of Congress from one time to another
under specific executive orders of the President of the







14















- a s edr tax returns under tho ap-











Howard M.Zari tsky
Legslative Attorney













THE GENERAL COUNSEL OF THE TREASURY
WASHINGTON. 0 C 20220


DEC 9 1975

Dear Mr. Chairman:

Reference is made to your request for the views of this
Department on S. 2352, "To amend the Accounting and Auditing
Act of 1950 to provide for the audit, by the Comptroller
General, of the Internal Revenue Service and of the Bureau
of Alcohol, Tobacco, and Firearms."

S. 2352 would authorize the Comptroller General to
conduct independent audits of the Internal Revenue Service
(IRS) and the Bureau of Alcohol, Tobacco and Firearms (ATF)
of the Department of the Treasury.

The Department believes that the bill would be significantly
improved by a provision stating that the General Accounting
Office .(CAO) audits of IRS and ATF could be initiated only
upon the request of specifically authorized congressional
committees which would delineate the scope of the activities
which are to be reviewed. The power to examine our unique
voluntary self-assessment tax system is such a vital responsi-
bility affecting all citizens that its oversight should be
authorized only by appropriate congressional committees.

Accordingly, if S. 2352, or other similar legislation
is adopted by Congress, it is the view of the Department that
it would contribute both to orderly tax administration and to
greater public confidence in the tax administration process
if such legislation were to specify formally the committees
of Congress which initiate GAO reviews, and to bar the
initiation of such reviews by the Comptroller General.

On the other hand, if Congress decides that the appropriate
course of action is to grant to the Comptroller General audit
authority with respect to the Internal Revenue Service and the
Bureau of Alcohol, Tobacco, and Firearms, whether or not such
audit authority can be independently exercised by the Comptroller
General, then we believe that the other provisions of S. 2352







16



-2-


of concern to t he Department strike a sat is factory balance
between t legi t iat e ne~ds of the GAO for access to tax
return ad tax rturn information and to returns under the
National Fireais Act in conductcg audits, on the one hand,
and the i sic rights of taxpayers and of persons filing returns
und~r th< Nationa1 Firearms Act to privacy, on the other.

Fa other, S. 2352 would -- and correctly -- recognize that
GAO audits are nct to affect the finality of findings or
de os of the Scretary of the Treasury or his delegate
undr section 6406 of the internal Revenue Code.

The DAartm~.nt asumes that the pattern and goals of GAO
audits cintipla~t d by S. 2352 would correspond to those
de scr ied in the iport of the House Government Operations
Co:ujtte on h.R. 8948. See H. Rept. No. 94-565, at page 7.
Thie I[ zmnt r~ec'-nds that this objective be reflected
in a: rate co::,ittee report language.

The Departrment has been advised by the Office of Management
and Bu2t that there is no objection from the standpoint of
the Administration's program to the submission of this report
to your Co ittee.


Sincerely yours,




General Counsel
Richard R. Alr~echt
The Honorable
Abe Ribicoff, Chairman
Covcnittee on Gcverrncnt Operations
United States Senate
Washington, D. C. 20510






17


The letter reproduced below and the attached enclosure
were sent on December 31, 1975 to Meade Whitaker, Chief Counsel,
Internal Revenue Service; Irvine Crawford, Associate Director,
General Government Division, General Accounting Office; and
Herschel F. Clesner, Chief Counsel, Commerce, Consumer and
Monetary Affairs Subcommittee of the House Committee on
Government Operations.

ABRAHAM RIBICOFF, CONN., CHAIRMAN
JOHN L. MC CLELLAN, ARK. CHARLES H. PERCY. ILL.
HENRY M. JACKSON, WASH. JACOB K. JAVITS, N.Y.
EDMUND S. MUSKIE, MAINE WILLIAM V. ROTH, JR., DEL.
LEE METCALF. MONT. BILL BROCK, TENN.
JAMES B. ALLEN. ALA. LOWELL P. WEICKER, JR.. CONN.
LAWTON CHILES, FLA.I c ie
SA M NUNN, GA.
JOHN GLENN, OHIO
RICHARD A. WEGMAN COMM ITTEE ON
CHIEF COUNSEL AND STAFF DIRECTOR
GOVERNMENT OPERATIONS
WASHINGTON, D.C. Z0510

December 31, 1975


Dear

Enclosed are draft amendments to H.R. 8948 which I have
prepared. The purpose of the amendments is to provide Congress
with the ability to oversee General Accounting Office activities
under H.R. 8948 in order to protect taxpayer privacy. At the
same time it is our desire not to alter the General Accounting
Office's authority or ability to independently exercise the
audit authority provided for in H.R. 8948. Also included
are a number of technical amendments.

Your comments and suggestions on these proposed amendments
to H.R. 8948 would be appreciated. We presently hope to consider
H.R. 8948 at a Committee on Government Operations mark-up early
in the next session of Congress.

Very truly yours,




David R. Schaefer
Counsel


Enclosures






18


Amendments to H.R. 8948 To Be Proposed by Senator Ribicoff



On page 2, line 22, strike out "section 4424(a)" and

insert in lieu thereof the following: "sections 4424(a)

and 6103".



On page 3 strike out lines 11 through 13 and insert
-he
in lieu thereof the following:
?Repi
"(3) The Comptroller General shall designate in
: he
writing those employees of the General Accounting Office who

need to have access- to tax return information identifiable
foil
to a particular taxpayer, Only those employees of the

General Accounting Office so designated shall have access
Gen(
to tax return information identifiable to a particular tax-
and
payer. The Comptroller General shall, from time to time,
esti
but not less often than once every 6 months, notify the
reti
Joint Committee on Internal Revenue Taxation, the Government

Operations Committees of the House of Representatives and

the Senate, the Commissioner of the Internal Revenue Service

and the Director of the Bureau of Alcohol, Tobacco and or

Firearms of the name and title of each officer or employee

of the General Accounting Office who is authorized by the

Comptroller General to inspect any tax return or tax return tio:

information identifiable to a particular taxpayer. any
par

evi









-2-


"(4) In addition to the regular reports to the

Congress pursuant to the provisions of section 312 of the

Budget and Accounting Act, 1921 (31 US.C, 53), the

Comptroller General shall submit an annual written report

to the Joint Committee on Internal Revenue Taxation and

the Government Operations Committees of the House of

Representatives and the Senate regarding the results of

the audit work performed under this subsection. Such

report shall include, but shall not be limited to, the

following:

"(A) The procedures and requirements which the

General Accounting Office, the Internal Revenue Service,

and the Bureau of Alcohol, Tobacco and Firearms have

established for protecting the confidentiality of tax

returns and tax return information made available to the

Comptroller General under this subsection;

"(B) The scope and subject matter of any audit

or other examination or review authorized under paragraph

(1) of this subsection; and

"(C) Any findings, conclusions, or recommenda-

tions developed by the Comptroller General as a result of

any audit or other examination or review authorized under

paragraph (1) of this subsection including any significant

evidence of inefficiency or mismanagement."






20


Technical Amendments




On page 1, line 9, strike out the comma after the

word "Tobacco".


On page 2, line 14, strike out the comma after the

word "Tobacco".




Amend the title so as to read:

"An Act to amend the Accounting and Auditing Act

of 1950 to provide for the audit, by the Comptroller

General, of the Internal Revenue Service and of the

Bureau of Alcohol, Tobacco and Firearms."










Department of the Treasury

Office of
Chief Counsel
Internal Revenue Service
Washington, D.C. 20224
JAN 9 i976




Mr. David R. Schaefer
Counsel
Committee on Government Operations
United States Senate
Washington, D. C. 20510

Dear Mr. Schaefer:

This is in further reply to your request for my
comments and suggestions regarding your draft amendments
to H.R. 8948.

First, I feel that you should reconsider your proposed
amendment on page 2, line 22.

The first proviso of paragraph (2) beginning on page
2, line 16 would permit GAO to disclose identifiable wag-
ering tax information only to a Congressional committee
described in section 6103(d) of the Internal Revenue Code,
that is, the Ways & Means Committee, the Finance Committee,
the Joint Committee on Internal Revenue Taxation, or a
select House or Senate committee or select joint committee
specially authorized by Congressional resolution to inspect
tax returns. The second proviso of paragraph (2) beginning
on page 2, line 24 is considerably broader. This proviso
would permit GAO to disclose identifiable tax information
other than wagering tax information to anyone to whom such
disclosure was authorized under any provision of section
6103.

The distinction drawn by these two provisos between
wagering tax information and other kinds of tax information,
such as income tax information, is extremely important. By
reason of section 4424, the circumstances under which






22


2-


identifiable wagering tax information can be disclosed
is severely restricted. Essentially, such information
can be disclosed only for federal tax administration
purposes or to a Congressional committee described in
section 6103(d) of the Code, i.e., one of those listed
above. These statutory limitations on disclosures of
wagering tax information responded to the decisions in
Marchetti v. United States, 390 U.S. 39 (1968) and Grosso
v. United States, 390 U.S. 62 (1968), which presented
constitutional questions regarding disclosures of wagering
tax information which could have effectively invalidated
the wagering tax provisions of the Code. Because of
section 4424, then, GAO disclosures of identifiable
wagering tax information must be dealt with separately
and made subject to more restrictive rules than those
applicable to other types of tax information.

The effect of your proposed amendment on page 2,
line 22 would be to subject GAO disclosures of all iden-
tifiable tax information to the restrictive rule designed
for wagering tax information. For example, your amendment
would prohibit GAO from disclosing any identifiable income
tax information to your own committee even though Executive
Order 11859 authorizes disclosures of such information
directly to the committee by the Internal Revenue Service.
In other words, GAO would be unable to act as agent for
your committee in conducting an audit of the Service. I
doubt that you intended this result.

Accordingly, I would suggest that page 2, line 22 of
H.R. 8948 not be amended.

Second, I am attaching for your consideration a
revision of your proposed amendment of paragraph (3) begin-
ning on page 3, line 11. The purpose of this revision is
to conform the language to some of that used in paragraph
(2) and to make it clear that the list of GAO employees
who are to have access to identifiable tax return infor-
mation must also include those who are to have access to






23


3 -


tax returns themselves and to any information described
in clause (B) of paragraph (2) which could identify a
taxpayer.

I have no problems with any of your other proposed
amendments. If you have any questions regarding my
revision, please give me a call or call David Dickinson,
a member of my staff, at 964-3363.

Sincerely yours,




Meade Whitaker
Chief Counsel


Attachment






24


On page 3 strike out lines 11 through 13 and insert

in lieu thereof the following:

"(3) The Comptroller General shall, from time

to time, but not less often than once every 6 months,

designate in writing the name and title of each officer

and employee of the General Accounting Office who, pursuant

to the provisions of paragraph (2) of this subsection, is

to have access to tax returns and tax return information,

or any information described in clause (B) of such paragraph

(2), in a form which can be associated with or otherwise

identify, directly or indirectly, a particular taxpayer.

Each such written designation, or a certified copy thereof,

promptly shall be delivered to the Joint Committee on Internal

Revenue Taxation, the Government Operations Committees of

the House of Representatives and the Senate, the Commissioner

of Internal Revenue, and the Director of the Bureau of Alcohol,

Tobacco and Firearms."










C. ROSENTHAL, N.Y., CHAIRMAN
CARDISS COU NS. ILL.
WMERT F DRINAN, MASS.
ELLIOTT 14. LEVITAS, GA.
DAVID W. EVANS, ID.
ANTHONY MOFFE'rr, COMM
ANDREW MAGUIRE, NJ.
EDWARD MEZVINSKY, IOWA


NINETY-FOURTH CONGRESS

Congre of tte Uniteb Sbtateo
Houet of Reprezsntatibez
COMMERCE, CONSUMER, AND
MONETARY AFFAIRS SUBCOMMITTEE
OF THE
COMMITTEE ON GOVERNMENT OPERATIONS
RAYBURN HOUSE OFFICE BUILDING, ROOM B-350-A-B
WASHINGTON. DC. 20515


Mr. David R. Schaeffer
Government Operations Committee
Room 3306 DSOB
Washington, D. C.


nuary 13, 197 6r- EA 0
YJiAN 16 197


7 7r,.' I TI t 1 i


Dear Mr. Schaeffer:


This is in reply to your letter of December 31, 1975.
the opportunity to comment on the draft amendments.


I appreciate


Regarding the proposed amendment, on page 2, line 22, I believe you
should not consider this amendment. I agree with the position of IRS'
Chief Counsel, Meade Whitaker, in his letter of January 9, 1976, to you.
He has set out the position which the members of the Subcommittee in its
working sessions evolved and adopted. The Subcommittee felt it was impor-
tant to make distinctions between the handling of wagering tax information
and other tax information because of the special constitutional questions
raised by the former. Your amendment would subject both kinds of informa-
tion to the same severe restrictions and thereby defeat necessary and
needed studies and investigations of regular IRS operations.

Your amendments to paragraph 3 are substantially acceptable; however,
your additional paragraph may result in an unnecessary and inadvisable
restriction on the use of the GAO report by the Congress. Enclosed is
a possible compromise which may avoid most of the objections and still
suit your purposes.

Because it would enable us to proceed without some of the conference
difficulties, I would appreciate it if you could use numbered amendments.

Sincerely yours,


-1 - "


Herschel F. Clesner
Chief Counsel


HFC:emv


Enclosure


GARRY 1110WN uIC1.
WILLIS 0 GOADiSON, Jt., OiO
.IO"" N ERLEN5-,,. ILL.
(2=2) 225-447


_ _/ 1" - , -,-,






26


"(4) The Comptroller General shall submit a[n annual

written] report [, as frequently as may be practicable,]

to the Congress regarding the results of the audit work

performed under this subsection. Such report shall include,

but shall not be limited to, the following:

"(A) The procetlures and reCquirei ents %>.iich the

General Accounting Office, the Internal Revenue Service,

and the Bureau of Alcohol, Tobacco and Firearms ,.ave

established for protecting the confidentiality of tax

returns and tax return information made available to th!e

Comutroller General under this subsection;

"(B) The scope and subject matter of any au.Jic

or other examrinaLion or review authorized unc .r p;:raira

(1) of this subsection; and
i(C) Any findings, conclusions, or ;ecomrx-n..z-

tiors developed by the Comptroller General as a resi:- of

any audit or other examination or review authorized ++ ner

paragraph (1) of this subsection including any siga i 7cn:

evidence of inefficiency or mismanagement."













UNITED STATES GENERAL ACCOUNTING OFFICE
WASHINGTON, D.C. 20548


OFFICE OF GENERAL COUNSEL
January 16, 197>





Mr. David R. Schaefer
Counsel
Committee on Government Operations
United States Senate

Dear Mr. Schaefer:

This is to advise that we have no objection to the
underlying intent of your suggested amendments to H.R. 8948.
We do, however, favor the Internal Revenue Service view
with regard to the amendment on page 2, line 22, concerning
section 6103. See Meade Whitaker's letter to you of
January 9, 1976.

On another matter, I wish to bring to your attention
the provisions of section 502(b) of the Energy Policy and
Conservation Act, Public Law 94-163, 89 Stat. 871, 957,
wherein the Comptroller General is specifically denied
access to energy information within the possession of the
Internal Revenue Service. Obviously section 502(b) was
enacted prior to the time that GAO's right of access to
IRS information was resolved. I think it important in
connection with the enactment of H.R. 8948 that provision
be made to avoid any future controversy over the intended
scope of authority being provided. This could be accomplished
by amending the subparagraphs numbered (2) (A) and (B) on
page 2 of the bill to read as follows:

"(A) shall, notwithstanding the provisions
of sections 4424 and 6103 of such Code and the
provisions of any other law, have access to tax
returns and tax return information described in
sections 4424(a) and 6103; and
(B) shall, notwithstanding the provisions
of any other law, have access to all other books,
accounts, financial records, reports, files,







28


papers, things, and property belonging to
or in use by the Internal Revenue Service
or the Bureau of Alcohol, Tobacco and
Firearms: "

Mr. Whitaker agrees with the need for these changes and
with the desirability of the general approach suggested.

Sincerely yours,



Milton J. Socolar

Deputy General Counsel


- 2 -







29


WASHINGTON OFFICE


. . . . N. . .it

AMERICAN CIVIL LIBERTIES UNION K K
410 FIRST STREET, S.E., WASHINGTON, D. C. 20003


GOVERNM ENT OPERA IONS COM ..


A


(202) 544 -1681

CHARLES MORGAN JR
Director
JAY A MILLER
ASsoC Rse Ci'ecto'
HOPE EASTMAN
Assoc ate O ector


7 January 1976


David Schaefer, Esq.
Senate Government Operations Committee
Suite 3308
Dirksen Senate Office Building
Washington, DC 20510

Dear Dave:

In connection with our conversation this morning
about your GAO bill, I thought you might find the
enclosed letter which we sent during the summer to
Senator Church of some interest. I came across it
while looking for something else.

I am looking forward to our lunch. See you then.


Warm


Eastman


Enclosure


HE/ls


KATHLEEN MILLER. Ad~mnStt~ltve A4ziis.of


- / -) S Y'E







30


Ar,1RIC~N CIVIL L LLRIIS UNiO .. ,Y,
410 FIRST STREET, S.C.. WASHINGTON. D. C. 20003 (20?) ) 44-1l81

CHAnt S OC t A J
JAY A 0+Lt[
HOFE (A TMIAN


July Ii, 1975

Honorable Frank Church
Chairman
Select Comittee on
Inteli gence Ouerax c ons
G-308
Diik en Senate Office Building
Wa.hington, D.C. 20510

Dear Senator Church:

Accords ng to thf s +r,,0g '2 WUo Post,
Attorney Gene,_ra1 T, .. ..:'B
wya vi ad C) U 2 e:to2 Kelley
t. C: ittee next eek
to eNplaJ n why rents which vou have requ.eted. In an Ap:il 28,
1975, F'eech before the Association of the Lar of
the City of e York the Attorney General aSse Ld
that the Justice Depart2Jent had an cli a ton to
protect the privacy of individuals !:!0ntioned i n
F.B.I. files from congressional scrutiny. The
Arerican Civil Liberties Union urgcs you to reject
this assertion as a basis for denying your Com-
mittee access to the materials you seek.

As far as we know, no one has appointed the
Attorney C2ecral the gu:r' an of hi o r privacy.
The Justice Department, \: 7ch vielatre th rights
of the individuals it ro ost ct,
not be to oL_ to ue t right of 'prY ivacy to
th.art I nvesticat on of .ts own :-vi co .uc Th
only cre e 7ay for the Deartment to t e th t
position is if it is ,i 'n to contact t ,-
on ,+.hen i:.fors~o Li.on xists, .o, tri>m th s
and i de Iy U] ir d C I en as to U et L r i. Com-
t tee shou id hive a.ce, Othc ,;ine, the D. p rtI:)ent
is ULin : privacy to shic~ld it, n oC)doing.

if it is n in to afr- r 'o such a pi cc ureC
the c '_izen is left ,+.++;+++ .e+ '' unless thIe


0 1 ; ; .' 1 i ; ; 1, / ''! p I C '4' 't "











Honorable Frank Church
July 11, 1975
Page 2


Committee has the means to conduct an effective
investigation which can stop the abuses. That
requires that the Committee itself have access
to the information. At that point, of course,
the serious obligation to prevent invasions of
privacy through disclosure of information on
individuals, accidently or by design, becomes
yours.

When invasions of privacy occur, the un-
doing of those wrongs sometimes Involves a
further dissemination of the improperly col-
lected information. This is often true in
court cases challenging abuses by the executive
branch where the court has had to see private
data in order to correct the abuse of privacy.
If the Committee affords private citizens a
chance to object before information on them is
made public, the invasion of privacy caused by
Com ittee access is a limited one which is not
really different from dissemination to addi-
tional officials within the Justice Depariient.
Here, however, the purpose is not to compound
the injury but to correct it. Thus the limited
invasion is outweighed by the need for congres-
sional action to end the illegal and unconsti-
tutional activities which prompted this investi-
gation.

It is vital to keep from being pushed into
oversimplified comparisons with the McCarthy era.
The unfortunate legacy of that whole terrible
episode is a distaste for aggressive congressional
inquiries. However, the evil there was congres-
sional inquiry into political beliefs and asso-
ciations protected by the First Amendment. That
is not involved here.

The procedures we propose would better pro-
tect privacy than leaving the disposition of these
files to the uncontrolled discretion of the Justice
Department which has engaged in conduct it now
seeks to conceal.

Sincerely yours,



Exeutive Director


AN: km







32


REPORTS ISSUE D BY THE GL;EA AC1U;TI.JG OFFICE
ON ACIIVIfILS ul TL.L LRNAL REVENUE SE!kVZZL
A ND Lu"7U .L TOBACCO
FOR THE 'ERIOD JAX1RY 1971 ThCUGH JANUARY l97


Report title Date issued

Settlement of accounts of accountable officers of
the Internal Revenue Service, Southwest Regional
Office, Dallas, Texas, through June 30, 1970 5-4-71

Settlement of accounts of accountable officers of
the Internal Revenue Service, Southeast Regional
Office, Atlanta, Georgia, through June 30, 1971 6-24-71

Administration of the Federal highway use tax by
the Internal Revenue Service, B-164497(3)
(Report to the Legal and monetaryy Affairs
Subcommittee, Committee on Government Operations,
House of Representatives) 5-15-72

Appropriations committees not advised on reprograming
of funds by the Internal Revenue Service, B-133373
(Report to the Appropriation Comnmittees of the
United States Senate and the House of Representatives) 5-1-73

Cost benefits realized by the Internal Revenue Service
as a result of using consolidated travel authori-
zation procedures (Report to the Fiscal Management
Officer) 6-6-73

Collection of taxpayers' delinquent accounts by the
Internal Revenue Service, B-137762 (Report to the
Joint Committee on Internal Revenue Taxation 8-9-73

Savings in manpower by deferring collection action on
low dollar business delinquencies, B-137762,
RESTRICTED (Report to the Joint Committee on Internal
Revenue Taxation) 8-9-73

Explosives: Licensin3 and enforcement efforts in
Chicago Region of the Bureau of Alcohol, Tobacco
and Firearms, B-179095 (Rcport tc the Honorable
John B. Anderson, House of Repr-senLatives) 4-5-74

Mandatory Tax Withholding R-conju:cnded for Agricultural
Employees, GGD-75-53 (Re~prt to the Joint Committee
on Internal Revenue Taxation) 3-26-75







33


Report title Date issued

Telephone Assistance to Taxpayers Can Be Improved,
GGD-75-69 (Report to the Joint Committee on
Internal Revenue Taxation) 6-10-75

Need to Revise Deposit System on Alcohol and
Tobacco Excise Tax Returns (Letter Report),
GGD-75-112 (Report to the Joint Committee on
Internal Revenue Taxation) 8-1-75

Proposed Changes in Estate Taxation, GGD-76-1
(Report to the Joint Committee on Internal
Revenue Taxation) 10-20-75

No Apparent Need to Regulate Commercial Preparers
of Income Tax Returns, GGD-76-8 (Report to the
Joint Committee on Internal Revenue Taxation) 12-8-75

Occupational Taxes on the Alcohol Industry
Should Be Repealed, GGD-75-111 (Report to the
Joint Committee on Internal Revenue Taxation) 1-16-76











WORK IN PROCESS BY THE
GENERAL ACCOUbiI NG OFFICE
FOR THE
JOINT COlhITTI' ON l! I"iN REVENUE TAXATION
AS OF MAP&H 1976


Subject of review

IRS' assistance to taxpayers in filing their
returns

IRS' selection and audit of fiduciary tax
returns

IRS' selection of individual tax returns for
audit

IRS' audit of individual tax returns

Regulatory inspection program in the alcohol
and tobacco industries administered by the
Bureau of Alcohol, Tobacco and Firearms

IRS' use of jeopardy and termination assessments


Repetitive audits of taxpayers by IRS


Waivers of the statute of limitations obtained
from taxpayers by IRS

Procedures followed by IRS in the seizure and
disposal of property

Extent of nonfiling of employment tax returns by
tax-exempt organizations

IRS' administration of taxes on self-employed
income

IRS' controls over access to tax information at
regional and district offices

IRS' controls over access to tax information at
service centers

IRS' controls over access to tax information at
the data center and the national computer center

IRS' use of monies to pay for confidential and
other information


Date requested


6-18-73


6-18-73


6-18-73

6-18-73


6-18-73

12-27-74

12-27-74


12-27-74


12-27-74


2-28-75


2-28-75


2-28-75


2-28-75


2-28-75


3-25-75











WOPK IN PROCESS BY T 1
GE:;TL ACCOULX;IXG OFICE
U : ER TAKE-N UYD D I1 I IS 0uL flU
AS OF -. Or-l. 1976

Subject of review


Adequacy of data base and reliability of
methods and procedures for estimating
Federal revenues

Review of IRS' tax administration system
involving redesign and implementation
of new data processing facilities











3 1262 09113 1572