11.5.1  Audit Process for General Accountability Office (GAO) and Treasury Inspector General for Tax Administration (TIGTA)

11.5.1.1  (08-21-2006)
Purpose

  1. To improve timeliness and accuracy of responses to General Accountability Office and Treasury Inspector General for Tax Administration findings and recommendations. To ensure responses are strategic and consistent with corporate messages and the Agency’s mission. To identify controversial or sensitive issues as soon as possible.

11.5.1.1.1  (08-21-2006)
Role of Executives

  1. Become familiar with audit process.

  2. Attend opening and closing audit conferences and stay involved in the audit process.

  3. Assume a proactive approach with oversight of the program in their functional areas.

  4. Reach agreement on early alerts and discussion drafts.

  5. Identify and help coordinate cross-functional issues outside their functional areas.

  6. Review responses to draft audit reports before signature by Commissioners/Deputy Commissioners.

11.5.1.1.2  (08-21-2006)
Role of Legislative Affairs

  1. Provide oversight of the audit process.

  2. Be the initial point of contact for GAO/TIGTA research projects and audit notifications.

  3. Be the liaison between management and GAO/TIGTA on resolution of problems encountered during the course of the audits.

  4. Provide guidance to the business units and other functional areas on the audit process.

  5. Identify audit stakeholders and assign audits as appropriate.

  6. Issue memoranda transmitting audit notification letters and draft/final audit reports to the appropriate offices.

  7. Review management responses to audit reports.

  8. Monitoring the audits to make sure the responses are sent in a timely fashion.

  9. Schedule and coordinate GAO opening and exit conferences.

  10. Responsible for delivering signed agency response to GAO and mailing 60-day response to Congress.

11.5.1.1.3  (08-21-2006)
Role of Business Unit/Operating Division

  1. Become familiar with programs and high-risk issues covered in audit reports.

  2. Attend opening and closing audit conferences and stay involved in the audit process.

  3. Answer auditors' inquiries and provide documents as requested during the course of the audit.

  4. Identify opportunities to address or clarify issues before the audit is completed.

  5. Stay in touch with the auditors during the course of the audit to ensure the audit is progressing smoothly and request immediate alerts from auditors on any important findings.

  6. Reach agreement on early alerts and discussion drafts.

  7. Prepare responses to audit reports and review for accuracy comments and statistical/financial data provided.

  8. Ensure timely responses to audit reports; develop as much of the response as possible during the course of the audit to ensure the due date is met.

  9. Identify and coordinate cross-functional issues within and outside their functional areas during the audit process to ensure adequate coordination in developing the responses to the audit reports.

  10. Develop realistic corrective action plans for audit recommendations, including setting realistic completion dates.

  11. Provide periodic status updates on the progress of open audits to the Audit Liaison.

  12. Bring audit concerns to the attention of the Audit Liaison and to the appropriate executives.

  13. Identify a contact within the office for each audit to coordinate the audit.

11.5.1.1.4  (08-21-2006)
Role of the Office of Management Controls

  1. The Office of Management Controls administers the Service's Internal Management Control Program for the Chief Financial Officer who is Treasury's designated Bureau Internal Control Officer (BICO). The Office ensures compliance with the Federal Managers Financial Integrity Act of 1982 (FMFIA), the Federal Financial Management Improvement Act of 1996 (FFMIA), GAO Standards for Internal Controls, the CFO Act, and relevant OMB Circulars, and Treasury Directives.

  2. The Office of Management Controls servers as the liaison between IRS operational components and the Treasury Department in implementing the IRS Management Control Program. Besides the duties listed below, the Office of Management Controls develops and issues IRM program directives, maintains a web site devoted to the program, and conducts periodic conferences and training classes throughout the year for functional program coordinators.

11.5.1.1.4.1  (08-21-2006)
Federal Managers Financial Integrity Act Responsibilities

  1. Carry out the Annual Assurance Process

    1. Prepare call memorandum.

    2. Review submissions from Division Commissioners and Chief Officers.

    3. Identity deficiencies and issues for FMC ESC review.

    4. Prepare draft assurance statement for Commissioner's signature.

    5. Coordinate review of draft assurance statement and corrective action plans with GAO and TIGTA.

  2. Monitor progress in closing Material Weaknesses and other identified control deficiencies. Provide staff support, and prepare agendas for the monthly Financial and Management Controls Executive Steering Committee meetings by reviewing the following:

    1. Material Weakness and National Significant Control Deficiency action plans.

    2. Issues identified during the Annual Assurance Process.

    3. Division Commissioner and Chief Officer issues identified during normal course of business.

    4. TIGTA:
      Draft and issued reports.
      Memorandum to the Commissioner on major challenges facing the Internal Revenue Service.
      TIGTA comments on the draft Assurance Statement.

    5. GAO
      Draft and issued reports.
      Major Management Challenges and Program Risks - Department of the Treasury.
      GAO comments on the Assurance Statement.

    6. OMB memorandum identifying programs and management issues most in need of reform.

    7. IRS Oversight Board Annual Report.

  3. Prepare minutes of FMC ESC meetings documenting decisions and assignments.

11.5.1.1.4.2  (08-21-2006)
Audit/Federal Managers Financial Integrity Act/Federal Financial Management Improvement Act Follow-up

  1. The Office of Management Controls tracks the status of all IRS Material Weakness, National Significant Control Deficiency (NSCD) and audit action plans and financial accomplishments in Treasury's Inventory Tracking and Closure System (ITCS) and, as appropriate, the IRS Remediation Plan. The information contained in these plans is used to assess the effectiveness and progress that IRS is making in correcting weaknesses and implementing recommendations.

  2. ITCS and Remediation Plan responsibilities include:

    1. Review and maintain complete and accurate records of IRS management control deficiencies and management responses, including report findings, recommendations and corrective action plans.

    2. Provide responsible officials with ITCS Verification Reports when new audit reports are entered into ITCS.

    3. Ensure management provides a concise description of milestones or corrective actions to correct a weakness or to implement a recommendation.

    4. Ensure management addresses and accounts for potential monetary benefits and implementation.

    5. Review all management status updates to ensure compliance with reporting requirements and enter updates to close or reschedule corrective actions.

    6. Monitor aged audit reports and potential financial enhancements and request periodic reviews of these items by management.

  3. Provide IRS management and functional coordinators with report on monthly open inventories, status of audit corrective actions, and Material Weakness and NSCD milestones.

  4. Represent the Bureau head in negotiating with Treasury, TIGTA or GAO staff the resolution of disputed management control issues.

  5. Evaluate audit follow-up performance and ensure that these evaluations are an integral part of the bureau's FMFIA program.

  6. Prepare monthly statistics, performance measures and reports to assist the Financial and Management Controls Executive Steering Committee (FMC ESC) and responsible officials in assessing audit inventory management.

  7. Reconcile audit inventory with Treasury data monthly; reconciles TIGTA Semi-Annual report and GAO Open Recommendations with IRS records semi-annually.

  8. Assist in quarterly Remediation Plan briefings or Treasury and Office of Management and Budget representatives.

11.5.1.1.5  (08-21-2006)
Role of the GAO/TIGTA Liaisons/Representatives

  1. The GAO/TIGTA Liaison/Representative is responsible for managing and coordinating with pertinent functional areas along with the Office of Legislative Affairs, the open audit inventory from the General Accountability Office (GAO) and the Treasury Inspector General for Tax Administration (TIGTA) audits or research projects. The liaison/representative will:

    1. Coordinate suggestions for TIGTA's Annual Audit Plan.

    2. Be the primary point of contact for their functional areas for the open audit process and for inquiries from auditors.

    3. Forward engagement letters, draft reports, and any other audit-related documents received from TIGTA, GAO, or the Office of Legislative Affairs to the appropriate offices within and outside their functional areas and request responses and/or status updates.

    4. Schedule TIGTA opening and closing and participate in all GAO opening and closing audit conference.

    5. Ensure that the lead executive attends the opening and closing conferences, fully understand the reports' findings and recommendations, and provide final comments before the draft report is issued.

    6. Help ensure timely management responses to auditors' inquiries and audit reports by : 1) answering inquiries from auditors or referring them to the appropriate sources for answers or data gathering, and 2) by reviewing for accuracy responses to draft audit reports before forwarding them to the Office of Legislative Affairs for review, at least five days before the due date of the management response.

    7. Answer inquiries from management and the Office of Legislative Affairs regarding the status of open audits.

    8. Maintain a file on each open audit with related documents such as engagement letter, draft report, management response, and final report.

    9. Provide periodic open audit reports to pertinent offices within their functional areas.

    10. Act as liaison between management and the Office of Legislative Affairs on resolution of problems encountered during the course of the open audits.

    11. Develop audit process guidelines and other helpful tools to share with managers within their functional areas.

    12. Provide guidance to management on the Audit Programs and give presentations to higher level officials, as necessary, on the status of their open inventory.

11.5.1.2  (08-21-2006)
Introduction to General Accountability Office Program

  1. The U.S. General Accountability Office (GAO) is an independent nonpartisan agency that works for the Congress. GAO audits show how the federal government spends taxpayer dollars.

  2. GAO gathers information to help Congress determine how well executive branch agencies are doing their job. GAO’s work routinely answers such basic questions as whether government programs are meeting their objectives or providing good service to the public. Ultimately, GAO ensures that the government is accountable to the American citizens. To that end GAO provides Congress with the best information available to help them arrive at informed policy decisions – information that is accurate, timely, and balanced.

  3. GAO has several audit teams dedicated to Internal Revenue Service (IRS) activities; these include the Tax Administration and Justice Team, the Education, Work Force, and Income Security Team, the Financial Management and Assurance Team, the Information Technology Team, and the Strategic Issues Team. This workforce is comprised almost exclusively of career employees who have a strong knowledge of IRS programs and policies.

  4. The Office of Legislative Affairs is the initial point of contact in an audit and the liaison between the IRS and GAO on resolution of problems encountered during the course of an audit. The Office of Legislative Affairs is also responsible for overseeing the audit process for the IRS.

  5. GAO notifies the Office of Legislative Affairs of a new audit. The Office of Legislative Affairs assigns the audit to the Business Unit Office Head who has jurisdiction over the subject matter. The Office of Legislative Affairs notifies the Business Unit Office Head and the Business Unit GAO liaison/representative and gives specific guidance on the audit process. The Office of Legislative Affairs schedules the opening conference, monitors the audit until it is completed, identifies sensitive issues during the audit, participates in audit meetings, reviews IRS audit responses for quality (tone, clarity, and content) and responsiveness to the recommendation, and ensures that the audit responses are delivered timely to GAO.

  6. The Business Unit stakeholders work with the GAO auditors during the review, identify sensitive issues to the Office of Legislative Affairs during the audit, schedule exit conferences or other meetings, and track the status of the agency's response to the audit in the Information Tracking System (i-TRAK), review and determine accuracy of audit findings and recommendations, and draft the agency response.

11.5.1.2.1  (08-21-2006)
New General Accountability Office Audits

  1. To notify the Internal Revenue Service (IRS) of a new audit, General Accountability Office (GAO) issues a letter addressed to the Commissioner of Internal Revenue from the GAO Director of Tax Issues, regardless of which GAO team will do the audit work. The letter is known as the " engagement or notification letter" . The letter is sent electronically to the Office of Legislative Affairs, Legislation and Reports Branch, which has responsibility for the coordination of the GAO audit program.

    Action/Task Lead Alternate
    Review the engagement letter and assign it to organization(s) which have jurisdiction over the subject matter. The organization(s) identified are commonly referred to as the "stakeholder(s)" . Office of Legislative Affairs 's GAO Program Manager (PM)  
    Identify a lead stakeholder, if more than one organization is involved in the subject matter. Office of Legislative Affairs 's GAO PM  
    Assign the review to a Legislative Affairs Officer, to work with the Business Unit liaison/representative. GAO PM/Legislative Affairs Officer  
    Prepare and issue to lead stakeholder a cover memorandum to transmit the electronic engagement memo, along with the engagement letter. All GAO liaisons/representatives receive the memorandum and letter. The purpose of the memorandum is to officially inform the Business Unit about the audit and identify the Legislative Affairs Officer facilitating the audit. The memo indicates whether this is a tax or non-tax review. See IRM 11.3. – Disclosure of Official Information. GAO Support Staff  
    Inform the Office of Legislative Affairs if contact is made by GAO before engagement memo and engagement letter are received. GAO Business Unit liaison/ representative  
    NOTE: Each Business Unit has identified a single point of contact to act as their liaison/representative    

11.5.1.2.2  (08-21-2006)
General Accountability Office Opening/Entrance Conference

  1. The General Accountability Office (GAO) protocols provide that an agency will attempt to arrange for its personnel to be available for an opening conference no later than 14 calendar days after receiving a request for a meeting. An executive or his/her designee from the lead stakeholder organization must be present at the opening conference. At the opening conference, GAO outlines the scope of their audit, locations to be visited, anticipated date of completion, the names of auditors working on the job, and background information. Headquarters or local office work should not begin until the opening conference has occurred.

    Action/Task Lead Alternate
    Schedule and coordinate the opening conference (contact lead stakeholder and other internal stakeholders, Liaison/Representative and GAO auditor(s)). Legislative Affairs Officer Lead stakeholder and GAO/internal stakeholder(s) GAO Liaison/Representative
    Ensure all parties with responsibility for the subject matter are invited, including GAO. Legislative Affairs Officer Lead stakeholder and GAO Liaison/Representative Internal stakeholder(s) GAO Liaison/Representative
    Ensure that the lead stakeholder executive attends the opening conference. Lead stakeholder GAO Liaison/Representative Legislative Affairs Officer
    Facilitate opening/entrance conference. Legislative Affairs Officer  
    Provide IRS contacts to GAO. Lead stakeholder executive Other internal stakeholder(s) GAO Liaison/Representative
    Prepare summary of opening conference. Legislative Affairs Officer Lead stakeholder GAO Liaison/Representative
    Identify sensitive audits and alert the Branch Chief, Legislation and Reports.

    Note:

    Sensitive audits may include high profile internal activities or operations, such as employee training, section 1203 issues, taxpayer customer service, filing season issues, etc.

    Legislative Affairs Officer Lead stakeholder GAO Liaison/Representative

11.5.1.2.3  (08-21-2006)
Subsequent General Accountability Office Audit Notification

  1. According to its protocol, General Accountability Office (GAO) notifies the IRS regarding subsequent activity on an open audit (i.e., expansion of audit sites, access to taxpayer information, and change in scope, or closing of an audit prior to the issuance of a report).

    Action/Task Lead Alternate
    Notify the appropriate Business Unit GAO liaison/representative by electronic memorandum of any subsequent audit activity. GAO Support Staff  
    Inform the GAO Program Manager immediately if the lead organization receives changes to the audit activity without a memorandum from the Office of Legislative Affairs. Lead stakeholder GAO Liaison/Representative GAO PM

11.5.1.2.4  (08-21-2006)
Site Visits by General Accountability Office

  1. Site visits take place after the opening conference. General Accountability Office (GAO) auditors who have been authorized to have access to tax information are listed on one of two authorization lists -- "List of GAO Personnel Designated to Have Access to Returns and Return Information," and/or "List of GAO Employees Designated as Agents of the Joint Committee on Taxation, Senate Committee on Finance and/or the House Committee on Ways and Means Authorized to Have Access to Tax Return and Return Information. "

  2. These lists are provided to the IRS semiannually, with monthly updates as necessary. The lists can be found on the IRS intranet at: http://www.hq.irs.gov/la. Once in the Office of Legislative Affairs Home Page, click on GAO/TIGTA located in the yellow dialog box on the left side of the page. Then click on -- "List of GAO Personnel Designated to Have Access to Returns and Return Information" . Both documents are under that listing.

  3. If the auditor is not on the list, the GAO Business Unit liaison/representative will notify the Legislative Affairs Officer identified in the engagement letter immediately and must not allow access to tax information. If the audit is not tax return or return information-related, the auditor may proceed with the audit with proper government identification.

  4. GAO sometimes contracts out audit services, and their contractors accompany them at local sites. In this instance, an IRS employee must accompany the group during the entire visit to ensure that the contractor is not allowed access to tax information.

    Action/Task Lead Alternate
    Notify appropriate Business Unit local offices of GAO site visits. Lead GAO Liaison/Representative and other Internal stakeholder(s) GAO Liaison/Representative. Legislative Affairs Officer
    If GAO auditor arrives without prior notice, request the assigned GAO job code and reason for visit and contact next highest level Business Unit GAO liaison/representative. Lead and Other Internal stakeholder(s) GAO Liaison/Representative  
    Contact the Legislative Affairs Officer handling the audit if the Lead stakeholder GAO Liaison/Representative is unable to verify the job code number or find the auditor’s name on the disclosure lists. Lead stakeholder GAO Liaison/Representative Legislative Affairs Officer
    Accompany GAO auditor through the site to ensure that questions and/or problems are addressed. Manager of site or designated employee  

11.5.1.2.5  (08-21-2006)
General Accountability Office Closeout at Local Sites

  1. As appropriate, after conducting work at a local site, General Accountability Office (GAO) staff will hold a closeout meeting with agency officials who are responsible for the operations of the local site(s). The purpose of the closeout meeting is to ensure that GAO staff has a full understanding of the information they have gathered at a local site and its relevance to the objectives in the engagement letter . At the closeout meeting, GAO staff may discuss the implications of the information gathered at that local site. Such discussions may identify additional relevant information and thus lead to further data gathering at the location. GAO’s preliminary conclusions or recommendations are not discussed at the closeout meeting.

    Action/Task Lead Alternate
    Schedule closeout meeting with GAO and agency officials responsible for operations at local site. Lead stakeholder GAO Liaison/Representative  
    Notify the Legislative Affairs Officer of sensitive or controversial issues surrounding the visit. Lead stakeholder GAO Liaison/Representative  
    The Legislative Affairs Officer will bring the issue to the attention of the Branch Chief, Legislation and Reports. Legislative Affairs Officer  

11.5.1.2.6  (08-21-2006)
General Accountability Office Exit Conference

  1. An exit conference is held at the end of an audit to verify that all information gathered is accurate. The exit conference is normally held at IRS' Headquarters. This ends the information gathering phase. This is also an opportunity for both sides to review the findings, discuss and clarify issues, and come to consensus. However, no information or agreement is provided in writing. An executive or designee must be present at all exit conferences. After the exit conference is completed, GAO uses the information gathered to compile the draft report.

    Action/Task Lead Alternate
    Schedule and coordinate exit conference. Legislative Affairs Officer Lead stakeholder GAO Liaison/Representative. Other lead stakeholder GAO Liaison/Representative.

11.5.1.2.7  (08-21-2006)
Responding to General Accountability Office Draft Reports

  1. At the conclusion of the information gathering, General Accountability Office (GAO) produces a draft audit report and requests a formal IRS response on the GAO findings and recommendations. GAO forwards an electronic copy of the draft report and cover letter to the IRS GAO Program Manager and Program Support Staff. The cover letter specifies a date for GAO to receive the IRS response. The Office of Legislative Affairs cover memorandum will also indicate the date the response is due in the Commissioner’s office for review and signature. The response must be in the Commissioner’s office five days prior to the date the response is due to GAO. GAO determines the response due date which can be from 7 to 30 days, depending on the urgency surrounding the issuance of the report.

    Action/Task Lead Alternate
    Assign the draft report an Information Tracking System (i-TRAK) number. i-TRAK is a tracking system for correspondence that requires an action and due date. The i-TRAK control will go to the Business Unit Head of Office, asking the official to draft the formal agency response letter for the Commissioner’s signature. If the response involves more than one Business Unit, the Office of Legislative Affairs cover memorandum will designate a lead stakeholder responsible for drafting the response. GAO Support Staff Legislative Affairs Officer
    Prepare a cover memorandum addressed to the lead stakeholder and distribute electronically to the GAO Business Unit Liaison/Representative. The memo and the i-TRAK control are sent at the same time to the Business Unit Head of Office. The memo includes the name of the Legislative Affairs Officer assigned to the audit, the date the signature package is due to the Office of Legislative Affairs for forwarding to the Commissioner for signature and due to GAO, and the i-TRAK control number. GAO Support Staff Legislative Affairs Officer
    Schedule a meeting with all IRS internal stakeholders and GAO, if deemed necessary. The meeting is scheduled to discuss the draft report’s content, findings, and recommendations, and to establish the agency’s position. This is the "exit conference" . Legislative Affairs Officer GAO Business Unit Liaison/Representative. Lead stakeholder GAO Liaison/Representative. Other interested GAO Liaison/Representative
    Inform Legislative Affairs Officer if an extension to the due date is needed. Lead stakeholder GAO Liaison/Representative  
    Request an extension of due date from GAO. In rare cases, the Comptroller General may grant an extension if the agency shows that an extension is necessary and will likely result in a more accurate report. Legislative Affairs Officer  
    Draft the response, containing planned corrective actions, along with estimated completion dates. Lead stakeholder GAO Liaison/Representative other internal stakeholders
    Forward a draft copy of the response to the Legislative Affairs Officer identified in the cover memo. Lead stakeholder GAO Liaison/Representative  
    Share draft with the Office of Communications, Communications and Liaison, to make certain that office is aware of issues that may require future public comment. Legislative Affairs Officer  
    Update the i-TRAK to reflect the current status of the draft response. Lead stakeholder designee  
    Update i-TRAK. Legislative Affairs Officer GAO Support Staff
    Review the draft response for quality (tone, grammar, and clarity) and examine the response to ensure it is responsive to the recommendations. If the Legislative Affairs Officer identifies a problem area, the Legislative Affairs Officer will bring it to the attention of the Branch Chief, Legislation and Reports. The Branch Chief works with the lead stakeholder to resolve the issues. Legislative Affairs Officer  
    Return the draft response to the lead stakeholder to make recommended changes. Legislative Affairs Officer  
    Update i-TRAK. Legislative Affairs Officer GAO Support Staff
    Prepare the response in final format for the Commissioner’s signature. This is referred to as the signature package. A staff summary sheet containing initials/signatures of the reviewers and a note to the reviewers containing a summary of the report and the response must accompany the signature package. Lead stakeholder GAO Liaison/Representative  
    Forward the signature package to the Branch Chief, Legislation and Reports for review to ensure the response is properly structured, responsive to the recommendations, and consistent with the Agency’s mission. Lead stakeholder GAO Liaison/Representative  
    Approve the response. Branch Chief, Legislation and Reports Legislative Affairs Officer
    Forward signature package to the IRS Commissioner for signature. The response must be in the Commissioner’s office five days prior to the due date to GAO. Legislative Affairs Officer GAO PM
    Update i-TRAK. Legislative Affairs Officer  
    Notify the IRS GAO Program Manager that the response has been signed. Commissioner’s Support Staff  
    Pick up the response and forward it to GAO. A copy is faxed and the original is either mailed or hand delivered. Legislative Affairs Officer GAO PM
    Provide a signed copy of the response to the GAO Support Staff and the lead stakeholder. Legislative Affairs Officer GAO PM
    Close out the audit response in i-TRAK. Lead stakeholder GAO Liaison/Representative  
         
         

    Note:

    Examples of IRS responses to GAO draft reports are found at the following web site: http://www.hq.irs.gov/la under the Audit Resource Center.

11.5.1.2.8  (08-21-2006)
General Accountability Office Final Reports

  1. General Accountability Office (GAO) publishes the IRS’ response to the draft report in its final report (commonly called a " blue book" ). If the IRS’ response is not received on time, GAO issues the final report without it.

  2. GAO final reports are delivered to the Office of Legislative Affairs for distribution. The GAO Program Support Staff will deliver final reports to the Headquarters office of the Commissioner, the Deputy Commissioners, all Business Unit Heads of Office, the Business Unit GAO liaison/representative stakeholders, and the Office of Assistance and Review under the Chief Financial Officer.

  3. If the GAO final report does not contain the IRS response letter, the GAO Program Support Staff will forward a copy of the response letter to the Office of Assistance and Review for the audit record.

  4. If the final report contains recommendations to the IRS Commissioner, the Commissioner must submit an update on the planned corrective actions that address the recommendations, along with estimated completion dates. The updated statement is sent to the Senate Committee on Governmental Affairs, the House Committee on Government Reform, and the House and Senate Committees on Appropriations, within 60 days of the report’s issuance date. This is called the 60-day letter. These letters are due in the Commissioner’s office five days prior to the date the response is due to the congressional committee office.

    Action/Task Lead Alternate
    Assign the final report an i-TRAK number. The i-TRAK control will go to the Business Unit Head of Office, asking the official to draft the formal agency response letter for the Commissioner’s signature. If the response involves more than one Business Unit, the Office of Legislative Affairs cover memorandum will designate a lead stakeholder responsible for drafting the response. GAO Support Staff Legislative Affairs Officer
    Prepare a cover memorandum addressed to the lead stakeholder and distribute electronically to GAO Business Unit Liaison/Representative. The memo and the i-TRAK control are sent at the same time to the Business Unit Head of Office. The memo includes the name of the Legislative Affairs Officer assigned to the audit, the date the response is due to the Office of Legislative Affairs and GAO, and the i-TRAK control number. GAO Support Staff Legislative Affairs Officer
    Inform Legislative Affairs Officer if an extension to the due date is needed. Lead GAO Liaison/Representative stakeholder  
    Request an extension of due date from House and Senate Appropriations Committees, House Government Reform and Senate Government Affairs Committees through GAO, or by contacting the congressional committee staff directly. GAO PM Legislative Affairs Officer
    Draft a response statement that contains updated planned corrective actions that address the recommendations, along with estimated completion dates. A note to reviewers containing a summary of the issues involved must accompany the response as well as a staff summary sheet. Lead stakeholder GAO Liaison/Representative Other internal stakeholders GAO Support Staff
    Forward a draft copy of the response to the Legislative Affairs Officer identified in the cover memo. Lead stakeholder GAO Liaison/Representative  
    Update the i-TRAK to reflect the current status of the draft statement. Lead stakerholder GAO Liaison/Representative GAO Support Staff
    Update i-TRAK. Legislative Affairs Officer GAO Support Staff
    Review the draft statement for quality (tone, grammar, and clarity) and examine the statement to ensure it is responsive to the findings or recommendations. If the Legislative Affairs Officer identifies a problem area, the Legislative Affairs Officer will bring it to the attention of the Branch Chief, Legislation and Reports. The Branch Chief will work with the lead stakeholder to resolve the issues. Legislative Affairs Officer  
    Return the draft statement to the lead stakeholder to make recommended changes, if any. Legislative Affairs Officer  
    Update i-TRAK. Legislative Affairs Officer GAO Support Staff
    Prepare the statement in final format for the Commissioner’s signature. This is referred to as the signature package. Lead stakeholder GAO Liaison/Representative  
    Forward the signature package to the Branch Chief, Legislation and Reports for review to ensure the statement is properly structured, responsive to the recommendations, and consistent with the agency’s mission. Lead stakeholder GAO Liaison/Representative  
    Approve the updated statement. Branch Chief Legislative Affairs Officer
    Forward signature package to the IRS Commissioner for signature. The response must be in the Commissioner’s office five days prior to the GAO due date. Legislative Affairs Officer GAO PM
    Notify the IRS GAO Program Manager that the response has been signed. Commissioner’s Support Staff  
    Pick up the response and forward it to the Congress. Legislative Affairs Officer GAO PM
    Provide a signed copy of the 60-day statement to the GAO Support Staff, the lead stakeholder, and Office of Assistance and Review. Legislative Affairs Officer GAO PM
    Close out the audit response in i-TRAK. Lead stakeholder GAO Liaison/Representative  
         

11.5.1.2.9  (08-21-2006)
General Accountability Office Limited Official Use Reports

  1. Sometimes a General Accountability Office (GAO) report is limited to internal and Congressional distribution because of its sensitivity. Examples are computer systems security, physical security, and compliance activities involving the Law Enforcement Manual (LEM). In these instances, GAO issues a Limited Official Use (LOU) report. These reports contain highly sensitive information and must be safeguarded in accordance with IRM Part 1.16.13, Information Protection, Minimum Protection Standards.

  2. At the conclusion of their audit work, GAO classifies sensitive draft reports as LOUs. These draft reports are issued directly to the lead stakeholder for comment. The GAO Program Support Staff does not receive or distribute a copy of the report but is notified by GAO that a LOU report has been issued.

    Action/Task Lead Alternate
    Prepare an electronic memorandum to the lead stakeholder with instructions to draft the response letter. This memorandum will include the title of the report, the response due date, and the i-TRAK control number. GAO Support Staff  
    Draft the response. Lead stakeholder GAO Liaison/Representative Other internal stakeholders, if applicable
    Monitor the due date of the response to ensure that the response gets to GAO on time; the response letter is not routed through the Office of Legislative Affairs for review. Legislative Affairs Officer  
    Forward signature package to the IRS Commissioner for signature. The response must be in the Commissioner’s office five days prior to the GAO due date. Lead stakeholder GAO Liaison/Representative  
    Notify the lead stakeholder that the Commissioner signed the response. Commissioner’s Support Staff Legislative Affairs Officer
    Pick up the response from the Commissioner’s Office and forward the letter to GAO. The letter may be faxed and the original hand delivered or mailed to GAO. Lead stakeholder GAO Liaison/Representative Legislative Affairs Officer
    Update i-TRAK and notify the Office of Legislative Affairs when the response is forwarded to GAO. Lead stakeholder GAO Liaison/Representative  

    Note:

    GAO includes the IRS response in the LOU final report. GAO delivers these reports directly to the IRS Commissioner and IRS stakeholders involved in the audit. Office of Legislative Affairs does not receive a copy of the report. The audit is considered closed once the final report is received by the Commissioner. For further information on GAO Disclosure Issues see IRM 11.3.23 – Disclosure to the General Accountability Office.

11.5.1.3  (08-21-2006)
Introduction to the Treasury Inspector General for Tax Administration Program

  1. Treasury Inspector General for Tax Administration (TIGTA) is organizationally placed within the Department of the Treasury, but is independent of the Department of the Treasury and all other Treasury offices, including the Treasury Office of the Inspector General (OIG). TIGTA focuses entirely on tax administration, while the Treasury OIG is responsible for overseeing the other Treasury bureaus.

  2. TIGTA’s Office of Audit identifies opportunities to improve the administration of the nation’s tax laws by conducting comprehensive, independent performance and financial audits of IRS programs, operations, and activities to:

    1. assess efficiency, economy, effectiveness, and program accomplishment;

    2. ensure compliance with laws and regulations;

    3. prevent, detect, and deter fraud, waste, and abuse.

  3. The TIGTA Office of Audit Program consists of reviews mandated by statute or regulation and sometimes at the request of IRS Management, as well as reviews identified through the Office of Audit’s planning and valuation process. TIGTA publishes an Annual Audit Plan at the beginning of each year.

  4. The Office of Legislative Affairs is the initial point of contact in an audit and is the liaison/representative between the IRS and TIGTA on resolution of problems encountered during the course of an audit. The Office of Legislative Affairs is also responsible for overseeing the audit process for the IRS.

  5. TIGTA notifies the lead Business Unit stakeholder and the Office of Legislative Affairs about a new audit. The Office of Legislative Affairs will notify Business Unit Office Head and the Business Unit TIGTA liaison/representative and gives specific guidance on the audit process. The Office of Legislative Affairs monitors the audit until it is completed, identifies sensitive issues during the audit, reviews IRS audit responses for quality (tone, clarity, content) and responsiveness to the recommendations, and ensures that the audit responses are delivered timely to TIGTA .

  6. The stakeholders work with the TIGTA auditors during the audit review, identify sensitive issues to the Office of Legislative Affairs , schedule opening and exit conferences or other meetings, update the audit tracking system, review and determine accuracy of audit findings and recommendations, and draft the agency response.

11.5.1.3.1  (08-21-2006)
Treasury Inspector General for Tax Administration Pre-Audit Activity

  1. Treasury Inspector General for Tax Administration (TIGTA) sometimes engages in pre-audit activities that do not warrant a formal audit notification letter. These situations can include audit planning and research activities (surveys, information gathering, etc.), and integrity projects. In these instances, a TIGTA staff person sends an electronically addressed letter to the Director, Office of Legislative Affairs and to the TIGTA Program Manager. The E-mail indicates the audit number, the scope of the work and the anticipated time frames. The Office of Legislative Affairs will provide a copy of this electronically to the Business Unit. An example of a pre-audit notification electronically can be found at the Office of Legislative Affairs web site www.hq.irs.gov/la/. Once in the site, click on Audit Resource Center, then Open Program Audit Desk Guide, then Pre-Audit phase.

  2. Legislative Affairs Officers and TIGTA liaisons/representatives and appropriate IRS officials must cooperate and provide TIGTA with requested information on pre-audit activities in the same manner as in a formal audit.

11.5.1.3.2  (08-21-2006)
New Treasury Inspector General for Tax Administration Audits

  1. To notify the IRS of a new audit, Treasury Inspector General for Tax Administration (TIGTA) electronically issues a memorandum addressed to the applicable Business Unit Head of Office from the Deputy Inspector General for Audit. The memorandum is known as the "engagement letter. " The engagement letter is also sent electronically to the TIGTA Program Manager and Support Staff, which has responsibility for the coordination of TIGTA audits within the IRS.

    Action/Task Lead Alternate
    Review the engagement letter and assign to Legislative Affairs Officer. TIGTA PM TIGTA Support Staff
    Prepare and issue an electronic cover memo and forwards, along with the engagement letter to lead stakeholder. All TIGTA liaisons/representatives receive the memorandum and letter. The purpose of the memorandum is to officially inform the Business Unit about the audit and identify the Legislative Affairs Officer facilitating the audit. The memo also provides guidance regarding disclosure issues. See IRM 11.3 Disclosure of Official Information. TIGTA Support Staff  

    Note:

    Each Business Unit has identified a single point of contact to act as the liaison/representative.

11.5.1.3.3  (08-21-2006)
Treasury Inspector General for Tax Administration Opening Conference

  1. The opening conference includes appropriate stakeholders and Treasury Inspector General for Tax Administration (TIGTA) auditors. It is imperative that an opening conference be promptly scheduled because TIGTA may begin local site work immediately after issuance of the engagement letter. An executive or his/her designee from the lead stakeholder organization must be present at the opening conference. The Legislative Affairs Officer must be notified of the scheduled opening conference, in the event that it is necessary for an analyst to participate.

  2. At the opening conference, TIGTA provides the scope of their audit, locations to be visited, anticipated date of completion, the name of the auditors working on the review, and background information.

    Action/Task Lead Alternate
    Schedule and coordinate the opening conference (contact lead stakeholder’s and other internal stakeholders’ Liaison/Representative, TIGTA auditor(s)), and Legislative Affairs Officer. Lead stakeholder TIGTA Liaison/Representative Legislative Affairs Officer/ other internal TIGTA Liaison/Representative
    Ensure all parties with responsibility for the subject matter are invited, including TIGTA. Lead stakeholder TIGTA Liaison/Representative Legislative Affairs Officer
    Ensure that the lead stakeholder executive attends the opening conference. Lead stakeholder TIGTA Liaison/Representative Legislative Affairs Officer
    Facilitate opening conference. Lead stakeholder TIGTA Liaison/Representative  
    Provide IRS contacts to TIGTA. Lead stakeholder Executive  
    Identify sensitive audits and alert the Branch Chief, Legislation and Reports.

    Note:

    Sensitive audits may also include high profile internal activities or operations, such as employee training, section 1203 issues, taxpayer customer service, filing season issues, etc.

    Legislative Affairs Officer Lead stakeholder TIGTA Liaison/Representative
         

11.5.1.3.4  (08-21-2006)
Local Site Visits by Treasury Inspector General for Tax Administration

  1. Treasury Inspector General for Tax Administration (TIGTA) may conduct local site visits after the issuance of the engagement letter. TIGTA auditors have authorized access to returns and return information as defined in 26 U.S.C. 6103(b). TIGTA personnel are authorized access to all facilities, the Oversight Board, and the Office of Chief Counsel (including computer facilities, computer rooms, electronic database and files, electronic and paper records, reports and records, as well as other material that pertains to the IRS programs and operations). See Treasury Order 115-01 on TIGTA’s web site at http://www.ustreas.gov/tigta/.

    Action/Task Lead Alternate
    Notify appropriate Business Unit local offices of TIGTA site visits. Lead stakeholder TIGTA Liaison/Representative Other internal TIGTA Liaison/Representative and Legislative Affairs Officer

11.5.1.3.5  (08-21-2006)
Treasury Inspector General for Tax Administration Closeout Meetings

  1. At the conclusion of local site work, Treasury Inspector General for Tax Administration (TIGTA) and the IRS may hold an informal closeout meeting. The purpose of the closeout meeting is to obtain local management input to the impending draft report and to obtain agreement to the facts.

    Action/Task Lead Alternate
    Schedule closeout meeting, if necessary, as determined by TIGTA and lead stakeholder management. Lead stakeholder TIGTA Liaison/Representative  
    Notify the Legislative Affairs Officer of sensitive or controversial issues surrounding the audit. The Legislative Affairs Officer will bring the issue to the attention of the Branch Chief, Legislation and Reports. Lead stakeholder TIGTA Liaison/Representative Legislative Affairs Officer
    Prepare a summary of the closeout meeting. Lead stakeholder TIGTA Liaison/Representative  

11.5.1.3.6  (08-21-2006)
Treasury Inspector General for Tax Administration Discussion Draft

  1. After the closeout meeting or conclusion of local site work, whichever is applicable, Treasury Inspector General for Tax Administration (TIGTA) usually prepares a Statement of Facts/Exit Point Sheet report summarizing the audit findings, conclusions, and recommendations. Statement of Facts/Exit Point Sheets must be shared by the lead stakeholder TIGTA Liaison/Representative with the Legislative Affairs Officer.

11.5.1.3.7  (08-21-2006)
Treasury Inspector General for Tax Administration Exit Conference

  1. An exit conference may be held at the end of an audit to verify that all information gathered is accurate. The exit conference includes all IRS stakeholders and Treasury Inspector General for Tax Administration (TIGTA). The TIGTA audit staff discusses with IRS management the audit results, conclusions, recommendations and outcome measures.

    Action/Task Lead Alternate
    Schedule and coordinate exit conference. Lead stakeholder manager and/or TIGTA Liaison/Representative  
    Notify the Legislative Affairs Officer of sensitive or controversial issues surrounding the audit. The Legislative Affairs Officer will bring the issue to the attention of the Branch Chief, Legislation and Reports. Lead stakeholder TIGTA Liaison/Representative Legislative Affairs Officer
    Prepare a summary of the exit conference. Lead stakeholder TIGTA Liaison/Representative  

11.5.1.3.8  (08-21-2006)
Responding to Draft Treasury Inspector General for Tax Administration Reports

  1. At the conclusion of the exit conference, Treasury Inspector General for Tax Administration (TIGTA) finalizes the Statement of Facts/Exit Point Sheet and prepares a formal draft report and requests a formal IRS response on the TIGTA findings and recommendations. The draft report and cover letter are forwarded electronically to the IRS TIGTA Program Manager and Support Staff. The cover letter gives a specified date for TIGTA to receive the IRS response. The IRS Commissioner and/or the lead stakeholder Business Unit Head of Office is requested to respond to the draft report within 30 calendar days. However, a shorter period may be set under certain circumstances, as determined by TIGTA.

    Action/Task Lead Alternate
    Assign the draft report an Information Tracking System (i-TRAK) number. i-TRAK is a tracking system for correspondence that requires an action and due date. TIGTA Support Staff TIGTA PM
    Prepare a cover memorandum addressed to the lead stakeholder and distribute electronically to TIGTA Business Unit Liaison/Representative. The memo and the i-TRAK control are sent at the same time to the appropriate Business Unit Head of Office. The memo includes the name of the Legislative Affairs Officer assigned to the audit, the date the response is due to the Office of Legislative Affairs and TIGTA, and the i-TRAK control number. If the response involves more than one stakeholder, the Office of Legislative Affairs cover memorandum will designate a lead stakeholder responsible for drafting the response. TIGTA Support Staff TIGTA PM
    Share draft report with the Office of Communications, Communications and Liaison, to make certain that office is aware of issues that may require future public comment. TIGTA PM  
    Inform Legislative Affairs Officer if an extension to the due date is needed. Lead stakeholder TIGTA Liaison/Representative  
    Request an extension of due date from TIGTA. The appropriate head of office responsible for the IRS response may need to request the extension from TIGTA at TIGTA's determination. Legislative Affairs Officer Lead stakeholder TIGTA Liaison/Representative
    Draft the response. Lead stakeholder TIGTA Liaison/Representative Other internal stakeholders TIGTA Liaison/Representative
    Forward a draft copy of the response to the Legislative Affairs Officer identified in the cover memo. Lead stakeholder TIGTA Liaison/Representative  
    Update i-TRAK. Legislative Affairs Officer TIGTA Support Staff
    Review the draft response for quality (tone, grammar, and clarity and examine the response to ensure it is responsive to the recommendations. If the Legislative Affairs Officer identifies a problem area, the Legislative Affairs Officer will bring it to the attention of the Branch Chief, Legislation and Reports. The Branch Chief will work with the lead stakeholder to resolve the issues. Legislative Affairs Officer  
    Return the draft response to the lead stakeholder to make recommended changes Legislative Affairs Officer TIGTA Support Staff
    Prepare the response in final format for the appropriate Business Unit Head’s signature. This is referred to as the signature package. Lead stakeholder TIGTA Support Staff  
    Forward the signature package to the Branch Chief, Legislation and Reports Branch for review to ensure the response is properly structured, responsive to the recommendations, and consistent with the agency’s mission. Lead stakeholder GAO SS  
    Approve the response. Branch Chief, Legislation and Reports Branch Legislative Affairs Officer
    Return the signature package to the Business Unit Head for signature. Legislative Affairs Officer TIGTA Support Staff
    Update i-TRAK. Legislative Affairs Officer TIGTA Liaison/Representative
    Notify the Legislative Affairs Officer that the response has been signed. Lead stakeholder TIGTA Liaison/Representative  
    The response is forwarded to TIGTA. A copy is faxed and the original is either mailed or hand delivered, and a copy is provided to the Legislative Affairs Officer. Lead stakeholder TIGTA Liaison/Representative  
    Provide a signed copy of the response to the TIGTA Support Staff. Legislative Affairs Officer  
    Close out the audit response in i-TRAK. Lead stakeholder TIGTA Liaison/Representative  

    Note:

    Examples of IRS responses to TIGTA draft reports are found at the following web site: http://www.hq.irs.gov/la, under the Audit Resource Center.

11.5.1.3.9  (08-21-2006)
Treasury Inspector General for Tax Administration Final Reports

  1. Treasury Inspector General for Tax Administration (TIGTA) electronically forwards the final report to Office of Legislative Affairs for distribution. Normally, there is no additional IRS response needed to a TIGTA final report.

  2. If TIGTA does not agree with any portion of the IRS response to their draft report, the final report will reflect the basis for disagreement. If there is significant disagreement with the IRS response, TIGTA will issue a memorandum to the Commissioner requesting a written reply to the Treasury Deputy Secretary, outlining the IRS's reasons for the lack of agreement on the report’s findings and recommendations. In these instances, Office of Legislative Affairs will issue a memorandum providing guidance.

    Action/Task Lead Alternate
    Distribute the final reports electronically to Business Unit TIGTA liaison/representatives, the Office of Assistance and Review (CFO), and the assigned Legislative Affairs Officer. TIGTA Support Staff  
    If the report does not contain the IRS response, forward a copy of the response to the Office of Assistance and Review for the audit record. TIGTA Support Staff  

11.5.1.3.10  (08-21-2006)
Treasury Inspector General for Tax Administration Limited Official Use (LOU) Reports

  1. Sometimes a Treasury Inspector General for Tax Administration (TIGTA) report is limited to internal distribution because of its sensitivity. Examples are computer systems security, physical security, and compliance activities involving the Law Enforcement Manual (LEM). In these instances, TIGTA issues a Limited Official Use (LOU) report. These reports contain highly sensitive information and must be safeguarded in accordance with IRM Part 1.16.13, Information Protection, Minimum Protection Standards.

  2. At the conclusion of their audit work, TIGTA classifies sensitive draft reports as LOUs. These draft reports are issued directly to the lead stakeholder for comment. The Office of Legislative Affairs does not receive or distribute a copy of the report but is notified of their issuance by electronically by TIGTA.

  3. TIGTA includes the IRS response in the LOU final report. TIGTA delivers these reports directly to the IRS Commissioner and IRS stakeholders involved in the audit. Office of Legislative Affairs does not receive a copy of the response. The audit is considered closed once the final report is received.

    Action/Task Lead Alternate
    Prepare an electronic memorandum to the lead stakeholder with instructions to draft the response letter. This memorandum will include the title of the report, the response due date, and the i-TRAK control number. Note: The response letter is not routed through the Office of Legislative Affairs because LOUs are not public documents. TIGTA Support Staff  
    Draft the response. Lead stakeholder TIGTA Liaison/Representative Other internal stakeholders, TIGTA Liaison/Representative
    Monitor the response to ensure that the TIGTA receives it on time. Legislative Affairs Officer  
    A signature package is sent to the appropriate Head’s office for signature. Lead stakeholder TIGTA Liaison/Representative  
    Pick up the response from the appropriate Head’s office and forward the letter to TIGTA. The letter may be faxed and the original hand delivered or mailed to TIGTA. Lead stakeholder TIGTA Liaison/Representative  
    Update i-TRAK and notify the Office of Legislative Affairs when the response is forwarded to TIGTA. The Office of Legislative Affairs does not receive a copy of the signed response. Lead stakeholder TIGTA Liaison/Representative  

11.5.1.3.11  (08-21-2006)
Treasury Inspector General for Tax Administration Disclosures Issues

  1. Treasury Order 115-01 provides that, in the course of their official duties, Treasury Inspector General for Tax Administration (TIGTA) personnel are authorized access to: Returns and return information as defined in 26 U.S.C. 6103(b); all IRS facilities, the IRS Oversight Board, and the IRS Office of Chief Counsel (including computer facilities, computer rooms, electronic database and files, electronic and paper records, reports and records, as well as other material that pertains to the IRS programs and operations). In addition, TIGTA personnel shall have access to similar facilities throughout the Treasury Department for matters within the jurisdiction of the TIGTA. See http://www.ustreas.gov/tigta/.

  2. The Treasury order covers all pre-audit activity and formal audits initiated by an engagement letter.

  3. Legislative Affairs Officers, TIGTA liaisons/representatives, and appropriate IRS officials must cooperate with TIGTA once the TIGTA auditor shows proper identification. If the TIGTA liaison/representative has questions regarding TIGTA’s presence, the liaison/ representative will consult with the Legislative Affairs Officer for resolution.

Exhibit 11.5.1-1  (08-21-2006)
Definitions

  Basic Terms Used in the Audit Program
60-Day Letter: Also referred to as the statement. The 60 day letter is an updated response to a GAO final report with recommendations. The IRS has sixty days to respond to Congress with the corrective actions to be taken and time frames within which they will be implemented to carry out the recommendation(s).
Alternate: Business Unit working with the lead on specific tasks during the audit process.
Audit: An examination of government programs, operations, and/or financial records. Audit is interchangeable or synonymous with "review " .
Blue Book: Also referred to as a final GAO audit report. The blue book is a final version of the GAO draft report.
Discussion Draft Issued by TIGTA and GAO at the conclusion of local site work. Provides local IRS management an opportunity to review the report for accuracy before issuance of a formal draft report.
Draft Report: A preliminary report of audit findings and recommendations prepared after completion of an audit. The IRS is given a specified time by GAO and TIGTA to respond to the draft report. A cover memorandum from Office of Legislative Affairs accompanies the draft report, and provides guidance for processing the draft report and IRS response.
Engagement Letter: A letter sent to the IRS from GAO or TIGTA providing notification of a new audit.
Engagement Memorandum: A memorandum sent to IRS stakeholders participating in the new audit from the Office of Legislative Affairs. The memo indicates which organization is the lead stakeholder, the name of the Legislative Affairs Officer assigned to the audit, and disclosure guidance.
Exit Conference: Meeting to discuss GAO's or TIGTA's preliminary findings and recommendations with Business Unit executive. Allows IRS to begin formulating its position on the findings and recommendations.
Final Report: The final report is the final version of the GAO or TIGTA draft report that may or may not contain modifications to the findings and recommendations identified in the draft report. The final report contains the IRS response to the draft report, if the response is received by GAO or TIGTA by the due date. Final reports maybe printed with or without the agency response. These reports are released to the public.
Lead, or Lead Stakeholder: Business Unit with primary responsibility for the subject matter of the audit and for specific audit process actions/tasks.
Liaison/Representative: Business Unit single point of contact responsible for audit activity within that particular Business Unit.
Limited Official Use Report: A draft or final GAO or TIGTA report limited to internal distribution because of its sensitivity. These reports are not released to the public. GAO limited official use reports are limited to certain internal IRS audiences and Congress.
Opening/Entrance Conference At the opening conference, GAO outlines the scope of their audit, locations to be visited, anticipated date of completion, the names of auditors working on the job, and background information.
Review: An examination of government programs, operations, and/or financial records. Review is interchangeable or synonymous with "audit " .
Signature Package: A folder containing the IRS response to a GAO or TIGTA draft report, along with supporting data or attachments, that has been cleared by the necessary parties and is ready to be signed by the IRS Commissioner, or the Business Unit Office Head. The signature package must include a note to reviewers, summary of the response, as well as a staff summary sheet.
Stakeholder: An organization or person with responsibility or a vested interest in the subject matter of an audit.
Statement: Also referred to as the 60-day letter. The statement is an updated response to a GAO final report with recommendations. The IRS has sixty days to respond to Congress with the corrective actions to be taken and time frames within which they will be implemented to carry out the recommendation(s).

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