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Market Segment Specialization Program (MSSP)

Reforestation Industry


Table of Contents


This report is a culmination of the results of the work performed by a team of individuals from Examination, Collection, and the State of Oregon Revenue Department. The primary objective of this group was to evaluate compliance within a specific group of taxpayers and to develop an industry/project report to be used as a reference tool by State and Federal examiners. A team audit approach was used to maximize audit resources and develop communication lines between the State of Oregon Revenue Department, the Examination Division, and the Collection Division of the Internal Revenue Service.

The team consisted of four revenue agents from Examination, one revenue officer examiner from Collection, one tax auditor from Examination, one revenue agent from the State of Oregon, and an audit accounting aide from Examination. The audit techniques presented in this report were used by the examiners and have been found to be useful within this industry.

The basic goals of the members of this team are outlined below:

  1. To determine if compliance was a problem in this industry.

  2. To determine if the contractors were filing all required Federal and State returns: Income tax, employment tax, and information returns.

  3. To determine if the Federal and State returns filed by the contractors were substantially correct.

  4. To make the appropriate recommendations to the proper State and Federal agencies, in order to strengthen voluntary compliance within this industry.

This report is based upon information gathered from a limited number of examinations. It is, therefore, not to be considered all inclusive or absolute as to its contents. The primary purpose of the report is to provide some general and technical information which should be useful to an examiner in the classification, pre-planning, and examination of returns selected in the reforestation industry.

The audit areas identified and discussed in this report were considered to be significant or unusual enough to warrant comment. The mere fact that an item is addressed in this report does not imply, in any manner, that it must or should be examined in every case. To the contrary, it is intended that the discussion for any one audit area will assist the examiner in deciding whether the item would warrant examination on a case by case basis. This handbook was developed as a reference tool and should be used as a supplement to the manual.

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Chapter 1 Return Selection Process

Returns Selected For This Project

Contractors were selected from the list of licensed Farm/Labor Contractor's, provided by the Bureau of Labor & Industry, Wage and Hour Division. A data base of the licensed contractors owning businesses in Salem, Woodburn, Mt. Angel, and the surrounding area was developed. AIMS was researched to locate social security numbers and addresses of the licensed contractors. Once a social security number was obtained, a transcript was ordered to determine if the contractors were filing Federal tax returns. Copies of selected contractors' returns filed with the State of Oregon were secured from the Department of Revenue under our information exchange agreement. The returns examined were selected based on prior knowledge of the types of expenses common to the reforestation industry and whether or not the items reported on the return appeared either large or unusual. The returns selected for examination were either individual Forms 1040, Subchapter S-Corporations, or C-Corporations. The group examined 9 prime contractors, 3 second-tier subcontractors, and 20 individuals who filed Federal returns Form 1040. The State of Oregon revenue agent examined the Corporate Income Tax Returns for three S-Corporations and one C-Corporation. The second-tier contractors were selected by expanding the "package audit" during the examination of the prime contractor. In other words, when a prime contractor was audited, the examiners reviewed certain documents (such as canceled checks, invoices, and Forms 1099) pertaining to subcontractor payments. The subcontractors who received large payments were identified and again transcripts were requested to determine if they filed Federal and State tax returns. We selected subcontractors that were filing employment tax returns and also subcontractors that were not filing either income tax returns or employment tax returns. During the classification process and the examination process, the group identified audit issues which appeared to be common within this industry. The following is a list of the audit areas that were identified:

  1. There were large numbers of nonfilers.

  2. Circumvention of employment tax liabilities and worker's compensation premiums by failing to file employment tax returns, paying wages in cash, and classifying all payments to workers as subcontractor payments.

  3. Employees in this industry are issued Forms 1099 for the above reasons. These individuals offset their Form 1099 income with expenses -- either paid by them or their employer, and subsequently qualify for a earned income credit.

  4. Sums of large amounts of income. Internal control is usually poor and leads to underreporting of income earned from Federal and State agencies, from other contractors, private companies, or other unrelated business activities.

  5. Poor accounting records lead to unsubstantiated expenses. Reforestation contractors contend that they do not have the expertise to maintain quality books and records.

  6. Returns are being prepared by unlicensed preparers. A preparer reported that he was being paid for bookkeeping services, not for preparing tax returns, and, therefore, was not required to sign the returns.

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Suggested Sequence Of Selecting Contractors For Examination

Step 1: Identifying the Prime Contractor

Reforestation contractors working in Oregon are required to obtain a Farm/Labor Contractor's License. To secure a listing of licensed Oregon contractors you need to contact the State of Oregon, Bureau of Labor and Industries, Wage and Hour Division. Oregon is the only known state that requires the contractors to have a license; however, the Bureau of Labor and Industries in your state will be able to give you more information on their policies.

Another possible resource for locating reforestation contractors is PSPB or the Department of Revenue in your state. PSPB and the Department of Revenue have the capability of running a listing of returns with specific Principle Industry Activity Codes, (PIA Codes). This may be something that your Disclosure Officer can secure for your area. Finally, you may be able to request a list of contractors from the Forest Service or the Bureau of Land Management. These agencies are required to maintain a current mailing list of contractors who wish to receive the current announcements of solicitations. Chapter 2 of this handbook, lists addresses, and telephone numbers of Oregon and Washington regulatory and licensing offices where you can secure information about reforestation contractors.

Step 2: Selecting Second-tier Contractors for Examination

While completing the expanded "package audit" the examiner should concentrate on those subcontractors with the highest dollar volume. A good starting point is to review the Forms 1099. In addition, the disbursements journal should be reviewed for other large volume contractors who were not issued a Form 1099, since, 1) the prime contractor may not be issuing a Form 1099 to all subcontractors, and 2) Forms 1099 are not required to be issued to corporations, and contractors are sometimes organized as corporations to circumvent the Form 1099 filing requirements.

Step 3: Identifying Disbursements to the Selected Subcontractors

In preparation for reviewing the key documents (canceled checks), disbursements made to the subcontractors selected in Step 2 must be identified by check number, date, and amount. It has been our experience that the contractors do not maintain summaries of their cash disbursement journal so it will be helpful to create a data base of payments made to individuals and the checks issued to cash. This information will be invaluable for the following reasons:

  1. The list will give you a starting point when analyzing a subcontractor's bank deposits since the contractor may be cashing payments received from the prime contractor at the prime contractor's bank.

  2. Prime contractors may be issuing checks to cash and paying the subcontractors in cash.

  3. The prime contractor may file a Form 1099, but exclude certain payments made to the subcontractor.

Step 4: Inspect Canceled Checks

The next step is to pull the checks for each selected contractor and to review the endorsements. The examiner will be looking for checks that were cashed in unusual ways. For example, they may have been converted to cashier checks, cashed at the payor's bank, cashed at a check-cashing business, deposited to a bank account located in another city, or endorsed to another individual. Because contractors normally operate as closely held family businesses, with few accounting controls in place, failure to deposit normal business receipts is a good indication that the income is not being reported for tax purposes.

Step 5: Select Subcontractors for Audit

After completion of Step 4, the examiner will have identified one or more contractors whose audits will spin-off. He or she would be well advised to request the payment detail for these contractors for the subsequent year as well. Requesting information in the early stages is advisable since it may become increasingly difficult to obtain documents as the audit progresses.

Step 6: Secure Documents for the Subcontractor File

The information to be accumulated for each contractor that will be spun-off should include as much of the following as is available:

  1. Forms 1099

  2. Front and back of all checks issued to the subcontractor

  3. Any identification information that the prime contractor may have on the subcontractor, such as past and current addresses, telephone numbers, business names, invoices, and social security numbers.

Step 7: Other Sources of Information for Locating Subcontractors

If the address or social security number retained by the prime contractor does not help you in locating the subcontractor, you can call the Corporate Commissioner to obtain the address of the business and the names and addresses of the registrants. We have found that it is common for individuals to register an assumed business name with the Corporate Commissioner and give the name and address of several registrants. (For information on Oregon businesses you can call (503) 378-4166). The Department of Insurance and Finance can be a helpful source for locating subcontractors. This agency maintains a list of individuals and businesses who currently have worker's compensation coverage. If the subcontractor currently has coverage, you can obtain .his or her home address. The Department of Insurance and Finance can also give you information about a business and tell you whether or not the business has registered for coverage as a partnership, corporation, or as a sole proprietor. (In Oregon you can call (503) 378-4954). As previously mentioned, the Bureau of Labor and Industries, Wage and Hour Division will have names and addresses of all licensed contractors. (In Oregon you may call (503) 378-3292).

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Chapter 2 Nature Of Operations

Overview Of The Industry

This MSSP Guide is designed to assist examiners in completing examinations of reforestation contractors. A contractor working in the reforestation industry may secure service contracts, (pre-commercial thinning and tree planting contracts) from a Federal agency, a State agency, from private companies, or other contractors. Keep in mind that State and Federal agencies issue several types of service contracts; examples are fire .fighting, cone collection, tree netting, tree shading, gopher baiting, etc. At this time it does not appear that the reforestation-station contractors bid for service contracts other than tree planting and tree thinning. However, no industry is stagnant and this may be something that contractors may expand into in the near future as they develop expertise in the reforestation industry. Since the most predominant type of service contract issued by the Federal and State agencies are pre-commercial thinning and tree planting contracts, the scope of this Guide has been limited to reforestation contracts only.

Federal and State Agencies Issuing Reforestation Contracts

The following Federal and State agencies have the .authority to solicit individuals to do pre-commercial thinning and tree planting:

  1. The Bureau of Land Management (BLM)

  2. The U.S. Department of Agriculture Forest Service

  3. The Small Business Administration Section 8A Program (the Small Business Administration under Federal Equal Opportunity regulations are set up to award, to qualified section 8A contractors, 10 percent of all Forest Service and BLM contracts. They do not monitor the contracts or make payments. The Forest Service or BLM continues to perform these services).

  4. State agencies, such as The Oregon Department of Agriculture Forest Service and Oregon Department of General Services.

Private Companies Issuing Reforestation Contracts

There are many private companies involved in producing timber products who may issue tree planting or tree thinning contracts, (that is, lumber mills, sawmills, veneer plants, plywood plants, and in some instances logging companies). Private companies issue tree planting or thinning contacts to either replant or maintain their own timber lands or to comply with the terms of a Federal or State contract. Certain states have legal requirements requiring all forest lands be replanted; these laws may cover both public and private lands. Private companies who purchase timber stands from Federal and State agencies agree to replant the land after harvesting the timber. There is a pattern of these private contractors employing the reforestation contractors on a regular basis.

Copies of contracts issued by private companies were requested; a review of these private contracts did not reveal any significant differences from those issued by the Federal and State agencies. The contracts reviewed by the group were written agreements between the company and the contractor and specify that the reforestation contractors will follow the applicable State and Federal laws while they are engaged to plant trees or for tree thinning.

Types of Contracts

This report concentrates on the requirements of securing contracts from the Federal and State agencies for two reasons: First, there are more contracts issued by the State and Federal agencies than by private companies. And secondly, it is more difficult to obtain information from private companies since this information is not public record as is the case with the Federal and State agencies.

Federal procurement regulations allow Federal agencies to solicit bids from prospective contractors for three major types of contracts: Service, supply, and construction. As previously mentioned, only service contracts are discussed since pre-commercial thinning contracts and tree planting contracts fall in this area.

Services are considered to be work that requires the direct engagement of the contractor's labor with the goal of performing an identifiable task rather than to furnish an end item of supply. This would include tree planting, tree thinning, cone collection, brush piling, etc. However, the term "service" excludes work done by the construction trades. (The group members have not researched either construction or supply contracts).

The State and Federal agencies have further divided thinning contracts into: 1) pre-commercial thinning contracts and 2) commercial thinning contracts. It becomes important to understand the difference between the two types of thinning contracts since it will enable you to be more successful in obtaining third party information. Probably the most important thing to remember is that these contracts do not fall under the same Federal Regulations nor will one contractor be qualified to work both types of contracts.

Pre-commercial thinning contracts are issued by the Forest Service to thin young forests (10 to 20 years of age). The young forests are thinned to cull undesirable trees, (such as oak, pine, and damaged firs) to give the remaining trees more room to grow.

Commercial thinning contracts, on the other hand, are .issued by the Forest Service to selectively harvest .mature trees. The Forest Service negotiates commercial .contracts have certain lands selectively harvested versus clear cut, as in the case of standing timber sales. Commercial thinning contracts are not considered to be reforestation contracts.

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General Requirements For State and Federal Agencies

Pre-commercial thinning contracts or tree planting contracts fall under State and Federal regulations. To illustrate, in the State of Oregon, to become a prime contractor the individual must provide the following:

  1. A valid Farm/Labor Contractor's License (applies in Oregon; check to see if there are similar requirements in your state).

  2. Verification of Worker's Compensation coverage.

  3. A Bid Bond or Performance Bond.

  4. Agreement, under penalties of perjury, to follow all State and Federal labor laws.

Federal and State contracts are guided by a series of laws and are enforced by several agencies. The Bureau of Land Management, the U.S. Department of Agriculture Forest Service, the Small Business Administration Section 8A Program, and the Oregon Department of Agriculture Forest Service enforce the operational aspects of the contracts guided by various Federal procurement regulations. Other Federal agencies, such as the Department of Labor and the Immigration & Naturalization Service, enforce regulations in relation to wages and the legal status of workers. State agencies are also involved. The state of Oregon's Bureau of Labor & Industry and the Department of Insurance and Finance enforce or monitor regulations governing licensing and Worker's Compensation coverage.

State of Oregon - Bureau of Labor and Industries - Wage and Hour Division - Oregon Farm/Labor Contractor's License

All solicitations for reforestation contracts (including, but not limited to, tree planting, brush clearing, and pre-commercial tree thinning, prescribed burn services, or contracts for cultivation of a crop) will contain the requirement for the Farm/Labor Contractor's Certification of Registration. A Notice to Proceed will not be issued without positive proof of the certification. Application for registration numbers would be made to the Department of Labor office.

The contractors are required to provide a bond before a Farm/Labor Contractor's License will be issued and provide a certificate of worker's compensation coverage. The cost of the license is $100.

Beginning July 1989, Wage and Hour Division is requiring a $10,000 bond, up from $5,000, and the contractors must take an examination before their license will be renewed. The examination pertains to the laws in various areas, (such as Worker's Compensation, Occupational Safety and Health Administration, Wage & Hour, and Forestry).

Once the contractor has received a license and begins working reforestation contracts, he or she must file a certified payroll every 35 days with the Bureau of Labor and Industries, Wage and Hour Division (BOLI). The certified payrolls will list employee names, their gross wages, and the amount withheld for taxes. BOLI uses the certified payrolls as a measurement device to determine whether or not contractors are complying with State wage and hour laws.

BOLI is looking for contractors who do not pay wages, since the failure to pay wages is grounds for withdrawing the Farm/Labor Contractor's License. All records maintained by BOLI are public. BOLI has changed the expiration date of the Farm/Labor Contractor's License to spread their workload. In prior years all licenses expired on January 31. Currently, the expiration date is determined as follows:

  1. The date of incorporation is the renewal date for all corporations.

  2. The date of birth of the oldest partner will be the renewal date of the partnership.

All partners in a partnership must now have a $10,000 bond. A lessor aggregate bond can be negotiated if the contractor has a clean record. The contractors are allowed a 25-percent reduction in the aggregate amount due each year their record stays clean. The minimum bond they would be required to provide would be $10,000 or 25 percent of the total aggregate, whichever is larger.

Example 1

The partnership has five partners. The total bonding due would be: 5 x $10,000 or $50,000. With a clean record it would be reduced to: $50,000 x 75 percent or $37,500. The next year with a clean record it would be reduced to: $50,000 x 50 percent or $25,000. The .next year with a clean record it would be reduced to: $50,000 x 25 percent or $12,500. This would the lowest amount the partnership would be allowed to pay. If 25 percent of the aggregate had equaled less than $10,000 then the partnership would be required to pay $10,00.

A corporation will have to provide a bond for the majority shareholder and any other active stockholder in the corporation. The same rules apply to the aggregation and reduction as with partnerships.

The prime contractors and all first-tier subcontractors shall be required to obtain and maintain a Farm/Labor Contractor's License. Contractors not having a current license will be required to furnish evidence of having obtained such license within 10 days after receipt of written notification of the contract award. Failure to obtain, keep, or maintain a current license during the term of this contract or the extension thereof shall be basis for termination or default.

Contractors living in Oregon may bid and receive contracts in other states, (that is, Northern California, Washington, Idaho, etc.). Oregon contractors are not required to have or maintain an Oregon Farm/Labor Contractor's License to work contracts outside of Oregon. However, Oregon contractors who have lost their license normally will continue working in the industry although they now are required to work outside of Oregon.

The Forest Service, the Small Business Administration, and the Bureau of Land Management do not have the authority to ensure that the first-tier subcontractors have a valid license. This causes concern because it allows the prime contractors to use unlicensed subcontractors. The system is not fail proof and Oregon contractors can find ways of hiring unlicensed contractors within the law. You could find an Oregon contractor paying subcontractor payments to a first-tier subcontractor who lives in Oregon but does not have a license. For example, a first-tier sub-contractor, whose tax home is in Oregon, works for an Oregon contractor in California. Whether or not the Federal agencies are able to enforce the licensing requirement at the first-tier subcontractor level depends on their working relationship with the prime contractor.

Another important point to remember is that the State of Oregon, Bureau of Labor & Industries, Wage and Hour Division has no authority to enforce the hourly wage rates set by the U.S. Department of Labor. The State of Oregon has no set amount that must be paid to reforestation workers, with the exception of the minimum hourly wage rate. According to BOLI, they have .tried to set a standard of $6 to $7 per hour for employees in this industry.

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Workers' Compensation Carrier - SAIF Corporation

According to the terms of the Federal and State pre-commercial thinning contracts and the tree planting contracts, all prime contractors must carry worker's compensation on their employees. SAIF requires that the prime contractor carry worker's compensation coverage regardless of whether or not their subcontractors are covered.

SAIF is only one of the companies providing worker's compensation in the State of Oregon. There are approximately 250 worker's compensation insurance companies covering the state. There are six large companies. The three main ones which would probably cover contractors in the reforestation industry are: SAIF, Liberty Northwest, and Employers of Wausau. The Oregon Worker's Compensation rates range from $51 to $34 per every $100 of payroll. This amount varies by year and will go up or down depending on the contractor's work record. According to SAIF, they have had instances where contractors in the assigned risk pool will pay $100 for every $100 of payroll. If you want to check to see if a contractor is currently covered by SAIF you can call (503) 373-8000. SAIF is authorized to release some information without .a subpoena. They can tell us if a contractor is insured, how much the contractor has paid in insurance premiums, how many days were worked, and the amount of payroll reported. We can subpoena their audit reports, correspondence or any claims filed against a contractor.

State of Oregon - Worker's Compensation

The Department of Insurance and Finance maintains a listing of employers who currently have worker's compensation as well as their coverage history. You can call the Employer Index at (503) 378-5540 to find out if any employer is currently covered, if they had coverage in prior years, and when their coverage was terminated. The Department of Insurance and Finance will only have information on employers who are required to have coverage. Employers are required to carry worker's compensation if they pay an employee $200 per month.

Reforestation contractors frequently change their business names and the registrants of the business. There could be several reasons why the contractors change the business name or registrants, including attempts to circumvent payment of Worker's Compensation. In Oregon, wage payments made to the owners of the business, (that is, the partners in a partnership, or officers of a corporation) are exempt from worker's compensation coverage.

The Department of Insurance and Finance can tell you if an individual or a business is registered with them as a partnership, corporation, or a sole proprietor. This information may be helpful in determining whether or not all required returns were filed.

The files kept by the Department of Insurance and Finance are public records. However, the Department will not have a file on an employer unless there has been a complaint filed against him or her. If an employee makes a complaint against an employer, Worker's Compensation will send out a Field Investigator.

Worker's Compensation is not concerned about the subcontractor issue because they can hold the prime contractor liable. In fact, they can go back to any State agency or private company who offered the contract, if the prime contractor did not provide worker's compensation. This has been true since 1979. As of July 1989, Worker's Compensation can now go back to any entity who issued the contract with the exception of the Federal Government.

Oregon contractors working in Washington must carry Washington worker's compensation if: 1) the contract exceeds 30 days, or 2) they hire Washington residents.

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State Regulatory and Licensing Offices

The following is a list of state regulatory and licensing offices from which third party information can be obtained.

1. Register Business/Incorporate/Assume Business Name:
Secretary of State, Corporate Division, 158 12th Street, NE, Salem, OR 97310-0210, PH: (503) 378-4166 Dept. Licensing Services, 405 Black Lake Blvd., Olympia, WA 98504, PH: (206) 753-4401
2. Tax Records:
Department of Revenue, 966 Central Street, NE, Salem, OR 97301, PH: (503) 945-8091 Department of Revenue, Mail Stop AX-02, Olympia, WA 98504, PH: (206) 753-5525
3. Compensation Insurance:
Dept. of Insurance & Finance, Worker's Compensation Division, 21 Labor & Industries Bldg., Salem, OR 97301, PH: (503) 452-0288 Dept. of Labor & Industry, 905 Plum Street, SE, Olympia, WA 89504, PH: (206) 956-4817
4. Farm/Forest Labor Contractor License:
Bureau of Labor & Industry, Wage & Hour Division, Licensing Unit, 1400 SW 5th, Room 305, Portland, OR 97201, PH: (503) 731-4074 Dept. of Labor & Industry, ESAC Division, 925 Plum Street, SE, Olympia, WA, PH: (206) 956-5315
State of Oregon, Bureau of Labor and Industries, 3865 Wolverine, NE Rm. E-1, Salem, OR 97303, PH: (503) 378-3292  

Bonding Requirements

Contractors are required to provide bid bonds and performance bonds in certain instances. The bond can be either a surety bond underwritten by a bonding company or the individual can put up cash or other liquid assets such as stocks and securities. The cash or other liquid assets would be placed in a escrow account and would be available for payment of any unpaid wages due the employees. The interest income earned from the escrow account belongs to the contractor. The performance bond is held in escrow for 150 days after the job is complete. If no complaints are filed, the bond is released.

Currently, Federal agencies are only requiring bonding on service contracts and tree planting contracts over $25,000. The State of Oregon requires a bid bond on all bids over $15,000.

Laws Administered by U.S. Department of Labor

The contractors are expected to comply with a number of laws that are administered by the Department of Labor .n the performance of a Federal contract. The following is a brief explanation of the more common laws with which contractors are expected to comply during the performance of the contracts:

  1. Service Contract Act of 1965, as amended: Wages Rates and Fringe Benefits for Service Employees.

    This law is applicable to employees working on Federal contracts which are principally for services, as follows:

    Contracts over $2,500 -- Payment of not less than wage rates and fringe benefits found by the Department of Labor to be prevailing in the locality or, in certain cases, wages rates, and fringe benefits contained in a predecessor contractor's collective bargaining agreement as provided in a wage determination, included in the contract. This law also contains record keeping and safety and health requirements. Exhibit 2-2 contains a copy of a Wage Determination letter which is enclosed in each contract solicitation package.

    Contracts of $2,500 or less -- Payment of not less than the minimum wage provided in Section 6(a)(1) of the Fair Labor Standards Act.

    Administered by: Employment Standards Administration, Wage-Hour Division (Safety and Health provisions are administered by the Occupational Safety and Health Administration (OSHA)).

  2. Contact Work Hours and Safety Standards Act: Overtime Pay: Safety and Health Requirements.

    This law and its implementing regulations require that all laborers and mechanics employed by contractors or subcontractors in the performance of most Federal service contracts exceeding $2,500 be paid overtime compensation at a rate of not less than one and one-half times their basic rate of pay for all hours worked in excess of 40 in a work week. The act also includes safety and health provisions.

    Administered by: Employment Standards Administration, Wage-Hour Division (Safety and Health provisions are administered by the Occupational Safety and Health Administration (OSHA)).

  3. Migrant and Seasonal Agricultural Worker Protection Act: Labor Standards Protection for Migrant and Seasonal Agricultural Workers.

    This law requires farm labor and forestry contractors, agricultural employers, and agricultural associations to observe certain labor standards when employing migrant and seasonal agricultural workers, unless exemptions apply. Only farm labor and forestry contractors are required to register with the Department of Labor. Worker protection includes: Vehicle and housing safety requirements; disclosure of wages, hours, and working conditions, maintenance of prescribed records; and itemized information concerning pay and withholding from earnings.

    Administered by: Employment Standards Administration, Wage-Hour Division.

  4. Federal Labor Law Enforcement: For information on any of the previously listed laws administered by the U.S. Department of Labor, you can contact the offices listed below:


    U.S. Department of Labor
    ESA, Wage-Hour Division
    540 New Federal Building
    1220 SW Third Avenue
    Portland, Oregon 97204
    PH: (503) 326-3052


    U.S. Department Labor
    ESA, Wage-Hour Division
    Room 1060
    Federal Office
    909 First Avenue
    Seattle, Washington
    PH: (206) 442-4482

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Page Last Reviewed or Updated: 27-Feb-2017