TAX

ADMINISTRATION

IRS Faces Several

Challenges as It

Attempts to Better

Serve Small

Businesses

United States General Accounting Office

GAO Report to the Chairman

Committee on Small Business

U.S. Senate

August 2000

GAO/GGD-00-166

United States General Accounting Office General Government Division

Washington, D.C. 20548

Page 1 GAO/GGD-00-166 Small Businesses

B-282856

August 10, 2000

The Honorable Christopher S. Bond

Chairman, Committee on Small Business

United States Senate

Dear Mr. Chairman:

Small businesses—a category that includes farmers, other self-employed

individuals, and small corporations and partnerships—are a diverse and

important group of about 40 million taxpayers that are responsible for

remitting nearly half of the taxes collected by the Internal Revenue Service

(IRS) annually.

Enactment of the IRS Restructuring and Reform Act of 1998 sent a strong

signal that Congress expected IRS to address the problems that taxpayers,

including small businesses, have with IRS. The Commissioner of Internal

Revenue has embraced the need for change so that taxpayers receive topquality service from IRS to help them understand and meet their tax

responsibilities. IRS has revised its mission statement and is on a path to

transform its culture to one that more fully embraces customer service as

a core organizational value. As part of this effort, IRS is well on the way to

restructuring its operations around specific groups of taxpayers. One new

organizational unit, known as the Small Business and Self-Employed

Operating Division (SB/SE) to become operational in October 2000, is to

focus on the needs of small businesses.

You asked us to determine how IRS’ reorganization plans address the

difficult issues that affect the interactions between small businesses and

IRS. As agreed with your office, our objectives for this report were to (1)

identify what factors, if any, complicate the interactions between small

businesses and IRS; and (2) determine how, if at all, IRS’ reorganization

plans address those factors.

From responses to a survey we conducted of 1,000 businesses and the

results of interviews with IRS officials and representatives of the small

business community, we identified the following factors that complicate

the interactions between small businesses and IRS:

• According to IRS, small businesses are more likely than other taxpayers to

have compliance problems. IRS data show, for example, that small

Results in Brief
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Page 2 GAO/GGD-00-166 Small Businesses

businesses tend to have more collection cases involving withheld

employment taxes than do larger businesses. Tax law complexity was the

most commonly mentioned reason why small businesses might have

trouble complying. Small businesses, like larger businesses, can encounter

such complex tax issues as employment taxes and depreciation and are

subject to multiple layers of filing, reporting, and deposit requirements.

However, small businesses may not always have the kind of resources

needed to deal with those complexities.

• IRS has not operated in a way that best enables it to serve small

businesses. IRS has been structured along functional and geographic lines,

with each function (e.g., customer service and collection) and each

geographic unit (e.g., district office) responsible for all types of taxpayers,

from individuals whose only income is from wages to multinational

corporations. IRS has also historically allocated most of its resources to

correcting problems after they occur rather than preventing problems from

occurring. A focus on back-end correction versus up-front prevention can

be especially problematic for small businesses that need assistance up

front and that, absent that help, are at a high risk of going out of business if

problems arise.

• Many small businesses in our survey population were unaware of various

services that IRS has developed specifically for small businesses, and

many others who knew of the services did not use them. Small business

representatives told us that small businesses are often reluctant to go to

IRS for help.

• When small businesses in our survey population used certain IRS services,

such as tax publications and toll-free telephone assistance, they were often

not happy with the experience. For example, they said that publications,

though easy to obtain, were not easy to understand, and telephone

assistance was not easy to access.

The various changes discussed in IRS’ plans for the new organization

indicate that it will be taking steps to address those factors that we have

identified as complicating the interactions between IRS and small

businesses. Although the new organization may not be able to do much to

reduce the tax law complexity facing small businesses, it should be better

able to help businesses deal with those complexities. For example, IRS’

plans clearly recognize that many small businesses are reluctant to go to

IRS for help, preferring instead to rely on tax practitioners. Thus, IRS plans

to partner with practitioners and other outside organizations to deliver
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assistance while focusing some of its direct service efforts on those small

businesses most in need of help (such as start-up businesses).

All of this assumes that the various changes discussed in IRS’ plans come

to fruition. However, implementing the new SB/SE operating division will

not be easy. For example, the diversity of the taxpayer population for

which the new operating division will be responsible could stretch the

capabilities of management and staff and dilute the division’s customer

focus. The new division also will be (1) hindered in its ability to deliver

new programs and services by antiquated information systems and a

shortage of employees with needed skills; and (2) challenged, as is all of

IRS, to develop an integrated performance management system that

creates incentives for employee behavior that supports organizational

goals.

In commenting on a draft of this report, the Commissioner of Internal

Revenue said that IRS was committed to implementing a customer-focused

organization that will benefit all taxpayers and that our report would help

IRS improve its products and services for small businesses.

IRS is in the process of implementing a major reorganization, which will,

among other things, structure the agency around four major operating

divisions, each responsible for a particular customer segment. One division

is to be responsible for small businesses. As part of its reorganization

effort, IRS has developed a definition of small businesses, which we used

in our work. Based on that definition, small businesses include

partnerships and corporations (including S corporations) 1 with assets of

$5 million or less and all self-employed individuals (also known as sole

proprietors).2

A large majority of all businesses are small businesses. To illustrate, IRS

data showed that of the about 6.1 million partnerships, S corporations, and

corporations that filed returns for tax year 1995, about 5.9 million (or 97

percent) reported total assets of $5 million or less. In total, according to

 

1

 Corporations with no more than 75 shareholders can elect to be treated as S corporations for federal

tax purposes if certain requirements are met.

2

 Self-employed individuals file a Form 1040 (U.S. Individual Income Tax Return) with either a

Schedule C (Profit or Loss From Business) or Schedule F (Profit or Loss From Farming) attached.

Background
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IRS, small businesses account for about 44 percent ($915 billion) of all

money collected by IRS annually.3

To identify factors that complicate the interactions between small

businesses and IRS, we conducted a survey designed to gather information

on (1) IRS services that small businesses have used, (2) their past

experiences with IRS, and (3) their views on various aspects of IRS

service. We sent the survey to a stratified random sample of 1,000

businesses representing a study population of 398,105 businesses

nationwide. We identified the study population from the membership list

of the National Federation of Independent Businesses (NFIB), whose

membership includes all business types (i.e., sole proprietorships,

partnerships, S corporations, and corporations) and a wide variety of

business operations.4

 NFIB officials told us that although NFIB is not

exclusively an organization of small businesses, nearly all of its members

are small businesses. We stratified our sample by type of business to

ensure that we obtained the views of self-employed individuals.5

 We

received 548 usable responses to our questionnaire—a response rate of 55

percent.

The results for our sample of 1,000 can be generalized only to the

population of NFIB members. Also, because our results pertain to a sample

of the study population, all results are subject to sampling errors. Unless

otherwise noted, all estimates of percentages in this report have a 95-

percent confidence interval of less than plus or minus 10 percentage

points. (See app. I for a detailed description of our sampling methodology

and app. II for a copy of our survey document and the results.)

In addition to the survey, we took the following steps to identify factors

that complicate the interactions between small businesses and IRS:

 

3

 The $915 billion includes individual and corporate income taxes, employment taxes, excise taxes, and

taxes withheld for employees.

4

 After considering a number of national organizations that represent small businesses, we chose NFIB

because its membership was the largest and included members from a wide range of business sectors.

We reached a general consensus regarding this choice with cognizant officials from IRS, the Small

Business Administration, and a number of other membership organizations that represent small

businesses.

5

 Our sample consisted of two strata, defined by NFIB’s classification—sole proprietorships and other

types of business structures. During our analysis, we did not find a statistical difference between those

describing their business as a sole proprietorship and other types of business structures. Therefore, we

are only reporting on only the accumulated results for the small businesses in our study population.

Scope and

Methodology
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• We interviewed IRS headquarters officials and visited 2 of IRS’ 4 regional

offices (Midstates and Western) and 3 of its 33 district offices (North

Texas; Northern California; and Kansas-Missouri).6 At the field locations,

we interviewed officials responsible for various IRS functions that have

dealings with small businesses (i.e., taxpayer education, customer service,

compliance, and taxpayer advocacy).

• We attended 4 of 14 focus group meetings that IRS held with small

business owners and self-employed individuals to identify the needs of

small business taxpayers. We also obtained the final report summarizing

the comments made by small businesses at all 14 meetings.

• We interviewed representatives from the Small Business Administration,

tax practitioner associations, small business associations, and conferees to

the White House Conference on Small Business.

• We used a structured interview to gather information from 10 small

business and tax practitioner associations.

To determine how IRS’ reorganization plans address the complicating

factors we identified, we analyzed IRS’ plans as they related to small

businesses and interviewed officials responsible for leading the teams that

developed those plans. We also discussed the reorganization plans with

officials from small business and tax practitioner associations.

We requested comments on a draft of our report from the Commissioner of

Internal Revenue, and those comments are reprinted in appendix III. We

did our work in accordance with generally accepted government auditing

standards between October 1999 and July 2000.

 

6

 Because we had no reason to believe that the kind of information we were gathering would be

affected by which regional office we visited, we judgmentally selected the Midstates and Western

Regional Offices. We visited the North Texas and Northern California District Offices because they

were located in the same areas as the two regional offices. We visited the Kansas-Missouri District

Office because of its convenience to our audit staff.
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Responses to our survey and the results of various interviews identified

the following factors that complicate the interactions between small

businesses and IRS:

• Small businesses have a greater potential for noncompliance than other

taxpayers,7

 primarily because they face the same complex requirements as

larger businesses without the kind of resources available to larger

businesses to deal with those requirements.

• IRS has not been operating in a way that best enables it to serve small

businesses.

• Many small businesses were unaware of key IRS services, and many who

know of the services did not use them.

• Many small businesses had negative reactions to their past interactions

with IRS, ranging from difficulties in understanding IRS publications and

accessing IRS’ telephone assistance to difficulties in resolving problems.

According to IRS, small businesses are more likely than other segments of

the taxpayer population to have problems complying with the tax law. For

example, IRS data show that (1) small businesses tend to have more

collection cases involving employment tax withholdings than large and

mid-sized businesses, and (2) self-employed persons and supplemental

income earners8

 make up about 40 percent of the examination and

collection cases involving individual taxpayers. Our interviews of IRS

officials and representatives of the small business community identified

several reasons why small businesses might have trouble complying.

The most commonly mentioned reason was complexity. According to IRS,

for example, although self-employed persons and supplemental income

earners are individual filers and, therefore, have characteristics similar to

individual filers whose only income comes from wages and investments,

self-employed persons and supplemental income earners face more

complex issues and file twice the number of forms and schedules.

Similarly, small corporations and partnerships, like larger businesses, can

 

7

 Noncompliance can mean any number of things, including an honest mistake that leads to an

incorrect tax return, a failure to pay income taxes on time, a failure to remit taxes withheld from

employees, and fraud.

8

 Supplemental income earners are wage earners who file a Form 1040 with a Schedule E for rental,

royalty, or other supplemental income. They are included in the population to be served by IRS’ new

organizational unit for small businesses.

Various Factors

Complicate the

Interactions Between

Small Businesses and

IRS

Small Businesses Have a

Greater Potential for

Noncompliance
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Page 7 GAO/GGD-00-166 Small Businesses

encounter such complex tax issues as those related to employment taxes,9

depreciation,10 and the alternative minimum tax11 and are subject to

multiple filing, reporting, and deposit requirements.12 Unlike larger

businesses, however, many small businesses may not have the kind of

resources on a continual basis that they need to understand and deal with

those complex issues and requirements.

Complexity is a key reason why an estimated 94 percent of our study

population used a paid preparer or accountant to prepare their tax year

1998 federal tax returns. Of those who used a paid preparer or accountant,

an estimated 36 percent said that they used a tax professional because the

tax laws and requirements are too complex; and another 56 percent said

that they would rather rely on a tax professional to ensure compliance.

Also, as shown in figure 1, a large percentage of the small businesses in

our study population relied on tax practitioners to understand various

complex issues that applied to their businesses.

 

9

 Employment taxes include Social Security and Medicare taxes, federal income tax withholding, and

federal unemployment tax.

10 Depreciation is the annual deduction allowed to recover the cost of business or investment property

having a useful life substantially beyond the tax year.

11 The tax law gives special treatment to some kinds of income and allows special deductions and

credits for some kinds of expenses. Taxpayers who benefit from the law in these ways may have to pay

at least a minimum amount of tax through an additional tax, called the alternative minimum tax.

12 The extent to which those issues and requirements apply to a specific business would depend on how

the business is organized, whether it has employees, and the nature of its business operations.
B-282856

Page 8 GAO/GGD-00-166 Small Businesses

Note: N = 398,105.

Source: Responses to GAO questionnaire.

Some of the respondents to our survey added narrative comments to

explain why they used a tax practitioner. For example:

“I rely on my CPA [certified public accountant] for all my taxes. There are too many forms,

rules, penalties, etc. for me to understand and keep up with. I have to try to make a living

through my small business and I am afraid I would do my taxes wrong if I tried to do them

myself. My CPA is very expensive, but I feel like I have to have one.”

“We depend almost completely upon our accountant in all of the previously mentioned

matters. The tax codes are far too complicated for the average small businessman to

tackle.”

Other factors mentioned by persons we interviewed as contributing to a

small business’ potential for noncompliance were that (1) business

income, unlike wages and investment income, is generally not subject to

withholding or some form of information reporting; and (2) small

businesses often have cash flow limitations. It is generally recognized that

Figure 1: Extent to Which Small

Businesses Relied on Practitioners to

Understand Tax Issues
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Page 9 GAO/GGD-00-166 Small Businesses

compliance is highest when taxes have been withheld (as is the case with

wages) or when a third party (such as a bank or mutual fund) reports

payments (such as interest and dividends) to IRS. Cash flow limitations

can cause a small business to become delinquent in making required tax

payments or in remitting taxes that have been withheld from employees.

IRS’ ability to meet the needs of small businesses has been hampered in

the past by its (1) organizational structure and (2) focus on problem

correction versus prevention.

Under IRS’ current organizational structure, authority for serving

taxpayers and administering the tax code is decentralized to 33 districts

and 10 service centers, each of which is organized along functional lines,

such as collection, examination, and customer service. Because IRS

allocates its resources, such as staff and information systems, along

geographic and functional lines, it is designed to handle a wide range of

issues pertaining to all taxpayers—from individuals whose sole income is

from wages to multinational corporations—with little or no focus on

specific taxpayer segments, such as small businesses. For example, IRS

has dozens of discrete databases that are function-specific and are

designed to reflect transactions at different points in the life of a return or

information report—from receipt to disposition. As a consequence, IRS

does not have any easy means to access comprehensive information about

small business taxpayer accounts.

IRS has described the problems caused by its organizational structure as

follows:

“Service centers and districts each performed these functions [e.g., collection, examination,

and customer service] for the same taxpayer, the responsibility shifting depending on

whether the work was done by phone, mail, or in person. For example, in the collection

area, there are three separate kinds of organizations spread over all 43 operational units

that use four separate computer systems to collect taxes. Each of these three units and four

systems collects from every kind of taxpayer, from individuals to businesses.”13

IRS’ ability to address small businesses’ needs has also been hampered by

IRS’ focus on correcting problems after they have occurred rather than

preventing their occurrence. According to IRS, it allocates about 11

percent of its budget for customer education and assistance (i.e., problem

prevention) compared to 72 percent for compliance (i.e., problem

correction). The other 17 percent is allocated to customer account

services, such as processing tax returns and adjusting taxpayer accounts.

 

13 Modernizing America’s Tax Agency, IRS Publication 3349, revised January 2000.

IRS Has Not Operated in a

Way That Best Enables It to

Serve Small Businesses
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Page 10 GAO/GGD-00-166 Small Businesses

This emphasis on correction versus prevention can be especially

problematic for small businesses that need assistance up front and that,

absent that help, are at a high risk of going out of business if problems

arise. In other words, by the time IRS determines that a small business has

a compliance problem and sets out to correct the problem, it may be too

late.

As shown in figure 2, many small businesses in our study population were

unaware of various IRS services that are available to small businesses,

such as outreach seminars and a small business corner on IRS’ World Wide

Web site on the Internet; and many other businesses who were aware of

the services did not use them.

Many Small Businesses

Were Unaware of Key IRS

Services and Many Who

Knew of the Services Did

Not Use Them
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Page 11 GAO/GGD-00-166 Small Businesses

Note: N = 398,105.

Source: Responses to GAO questionnaire.

Our survey results were consistent with many of the views expressed by

participants in IRS’ 14 small business focus groups. For example,

according to IRS’ report on the focus group results, most participants did

not know that IRS maintained an Internet presence and few participants

had heard about IRS-sponsored seminars.

Many of the focus group participants indicated that they had limited

familiarity with or use for IRS’ products and services because they relied

on tax practitioners. Small business representatives told us that small

Figure 2: Awareness and Use of

Selected IRS Services Among Small

Businesses
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Page 12 GAO/GGD-00-166 Small Businesses

businesses would rather rely on tax practitioners because they are too

busy, they do not trust IRS, or IRS’ services are not conveniently offered.

For example, one small business owner responding to our survey

commented that certain IRS services, such as walk-in sites and outreach

seminars, are not available in small towns and that it would be helpful if

there was more information available on IRS’ Internet site. Another small

business owner commented that he would personally find it difficult to

contact any source other than a local tax preparer for information because

of fear of an audit. He further suggested that IRS needs to change the

image that it treats small businesses as tax cheats.

Small businesses can have a variety of interactions with IRS ranging from

general written advice, such as that provided through tax publications; to

more personalized service, such as that provided over the telephone or at

walk-in sites; to enforcement actions, such as audits. Negative reactions of

small businesses to any such interactions in the past can complicate their

future interactions with IRS.

Our survey included several questions about small businesses’ interactions

with IRS over the past 5 years, including their level of satisfaction or

dissatisfaction with several aspects of IRS’ service. More small businesses

in our study population were satisfied with the overall quality of IRS’

service than were dissatisfied. However, as shown in figure 3, when asked

about specific aspects of IRS’ service, small businesses had mixed feelings.

For example, when asked about the availability of forms and publications

or IRS’ timeliness in issuing refunds, many more businesses commented

positively than negatively. The opposite was true, however, when they

were asked about such things as the understandability of forms, the

accessibility of IRS’ telephone assistance, and the levying of penalties.

Small Businesses Had

Mixed Feelings About Their

Past Interactions With IRS
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Page 13 GAO/GGD-00-166 Small Businesses

Note 1: N = 398,105.

Note 2: Percentages do not add to 100 because this figure does not include responses from

businesses who said that they neither agreed nor disagreed or who said that they had no basis to

judge.

Source: Responses to GAO questionnaire.

Several respondents who expressed dissatisfaction with certain aspects of

IRS’ service provided narrative comments to explain their feelings. For

example, one respondent commented that IRS’ instructions have too much

fine print and not enough plain English. Other examples include the

following:

Figure 3: Reaction of Small Businesses

to Selected Interactions With IRS
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Page 14 GAO/GGD-00-166 Small Businesses

“When I do finally get a phone call through, I [dislike] all of the menus that you go through

and the passing from one person to another when you finally do get to talk with a human. I

also despise the noncaring, uninterested attitude that I usually get from IRS employees.”

“The frustrating thing about [IRS] is they send you a notice about tax discrepancies, you

answer and about a month later you get another notice. You answer again and then you get

a notice telling you this is your final notice. They need to have a person assigned to your tax

problem so you could call them and work it out. It seems most of the time the person

sending you the notice never sees your replies.”

“IRS employees on the whole do not seem helpful or knowledgeable. Plus, each time you

call on a situation you have to start over each time with another employee. Problems

should be assigned to one person to follow through to the end.”

“During any type of audit or inquiry, IRS personnel generally treat taxpayers as ignorant

boobs who obviously are lying on their tax returns and it is only a matter of time until it can

be proven.”

Among the few positive comments provided by respondents were the

following:

“I must say that the auditor was flexible in that he was willing to review the records at our

accountant’s office and also was willing to accept receipts over a certain dollar amount in

order to facilitate the record-producing process. Also, we were treated very well by the

auditor, which we appreciated.”

“The IRS telephone assistance people have been very professional with me and have an

attitude of cooperation.”

We asked respondents whether they had seen any change in the overall

quality of IRS’ service during the year preceding our survey. Of the 398,105

small businesses in our study population, an estimated 45 percent had seen

no change, an estimated 14 percent had seen a positive change, and an

estimated 2 percent had seen a negative change.14 Some small business

owners responding to our survey mentioned changes they would like to

see. For example, one owner commented that IRS employees should have

a more positive attitude toward small businesses—a view shared by small

business owners who participated in IRS’ focus groups. Another survey

respondent said that:

“As much publicity as there has been about good intentions, I have seen no improvement in

how the IRS operates. To some extent, the IRS is no better or worse than other federal

agencies, none of them very good by the standards a for-profit business must operate

under.”

 

14 The other 38 percent had no basis to judge. These percents do not add to 100 because of rounding.
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Page 15 GAO/GGD-00-166 Small Businesses

Some small business owners and representatives said that although IRS

can improve its services, dissatisfaction with IRS is often misplaced. For

example, one small business representative said that many small

businesses that are dissatisfied with IRS have likely had little experience

with IRS and are really expressing their dissatisfaction with the complex

tax code. Misplaced or not, the level of dissatisfaction with various aspects

of IRS’ service expressed by our survey population is significant and can

complicate the relationship between small businesses and IRS.

IRS is implementing a major reorganization that it has characterized as its

most significant reform effort in more than 50 years. As shown in figure 4,

the reorganization is to, among other things, structure the agency around

four primary customer segments and operating divisions. One of those

operating divisions—SB/SE—is to focus on taxpayer education and

assistance, specialized account services, and revamped compliance efforts

tailored to small businesses and other taxpayers that IRS has decided have

needs and interests that are similar to those of small businesses.

Reorganization May

Enable IRS to Address

Many of the Factors

That Have

Complicated Its

Interactions With

Small Businesses
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Page 16 GAO/GGD-00-166 Small Businesses

Source: IRS.

The various changes discussed in IRS’ plans for the new organization

indicate that SB/SE will be taking steps to address those factors that have

been identified as complicating the interaction between IRS and small

businesses. Although the new organization may not be able to do much to

reduce the tax law complexity facing small businesses, it should be better

able to help businesses deal with those complexities and increase

customer satisfaction. By dedicating an operating division to small

businesses, increasing its knowledge base on the characteristics and needs

of the population, and customizing its products and services to meet those

needs, IRS intends to shed the limitations of its historic structure and

improve its customer focus.

SB/SE might be able to implement some of its plans relatively quickly, such

as those that involve partnering with outside organizations to enhance the

delivery of assistance to small businesses. Other plans, such as those

involving a revamped compliance strategy, could take much longer. Such

things as the diversity of the small business population, antiquated

computer systems, and staffing limitations pose challenges for the division,

and IRS in general, as they attempt to implement the new organization.

Figure 4: Structure of IRS’ New Organization
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Page 17 GAO/GGD-00-166 Small Businesses

With respect to small businesses, IRS’ goal is to improve customer

satisfaction and increase voluntary compliance through earlier and quicker

resolution of problems. To achieve that end, SB/SE is to have the following

three major units:

• Taxpayer Education and Communication is to manage both national and

local education and assistance programs for small businesses.

• Customer Account Services is to process returns and provide specialized

account services for small businesses.

• Compliance is to conduct compliance operations based on an approach

that combines education, community outreach, and traditional

enforcement actions (i.e., examinations and collections) based on the

facts, circumstances, and risks of each small business case.

As we discussed earlier, IRS’ ability to meet the needs of small businesses

has been hampered in the past by its focus on correcting problems after

they occur (i.e., compliance) rather than preventing them from occurring

(i.e., assistance). IRS has recognized the need for a greater focus on

assistance and (1) is placing the Taxpayer Education and Communication

unit on the same organizational level as the Compliance unit and (2)

intends to increase the number of staff dedicated to small business

education and communication from fewer than 100 in its current

organization to about 1,300 in the new organization. As currently

envisioned, the Taxpayer Education and Communication unit is to be a

customer-focused organization that educates and informs SB/SE taxpayers

about their tax obligations by conducting research on customer education

needs, developing and delivering products and services focused on those

needs, and analyzing customer feedback to improve products and services.

Although IRS intends to increase its taxpayer assistance and education

efforts, it recognizes that many small businesses are reluctant to go to IRS

for help. Thus, to increase the effectiveness of its education and assistance

efforts, IRS intends to partner with tax practitioners and professional trade

organizations to develop and deliver education and assistance to this

population.

In considering its options for partnering, IRS might find it useful to know

that many potential non-IRS sources of tax information were rarely used

by our survey population. As shown in table 1, when asked from which

non-IRS sources they had obtained tax-related information during the past

Operating Division

Dedicated to Small

Businesses Is Intended to

Improve Service and

Accountability

Taxpayer Education and

Communication
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Page 18 GAO/GGD-00-166 Small Businesses

5 years, the only sources mentioned extensively were attorneys,

accountants, and other tax practitioners.

Non-IRS source

Percent not

aware of

source

Percent aware of

source but have not

used

Percent aware of

source and have

used

Tax practitioner or accountant 5 7 88

Attorney 11 54 35

Local bank 34 48 18

Local library 24 65 11

Local college or community

college class 33 59 8

Small Business

Administration information or

development center 38 54 8

Small Business

Administration Web site 41 53 6

Source: Responses to GAO questionnaire.

IRS also intends to focus its assistance on those small businesses most in

need of help. One group of small businesses that IRS has identified as

needing special attention is new businesses. The Commissioner of Internal

Revenue discussed this need in May 23, 2000, testimony before this

Committee, as follows:15

“. . . there are as many as one million start-up businesses each year in the United States.

However, we now reach only 65,000 of them through our extremely limited education

outreach program, missing an enormous window of opportunity to help these taxpayers

understand what is expected of them and stay in compliance from the start.”

A cognizant IRS official told us that SB/SE is reviewing the assistance

currently provided to new businesses and that the division, through

consultations with the tax practitioner community, might establish a

system that will help SB/SE decide, on a case-by-case basis, what form of

interaction would be best for a particular start-up business.

As discussed earlier, under IRS’ functional structure, IRS employees have

been responsible for understanding tax law and filing requirements and

providing account management for all taxpayers—from wage earners to

large businesses—with little or no focus on small businesses. SB/SE, on

the other hand, is to have five account management centers dedicated to

 

15 IRS Restructuring: A New Era for Small Business (May 23, 2000).

Table 1: Non-IRS Sources of Tax

Information

Customer Account Services
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Page 19 GAO/GGD-00-166 Small Businesses

serving small businesses16 as well as dedicated phone sites to handle such

activities as tax law assistance and automated collection for small

businesses. According to IRS, this will allow SB/SE staff to become experts

in only those tax code sections and filing requirements that apply to small

businesses and, thus, provide specialized account assistance.

IRS expects to customize account management activities for small

businesses17 and provide more timely and accurate account resolution

through a short and long-term strategy for real-time account services. IRS

expects to transition the Customer Account Services workload between

October 2000 and 2002, but many of the unit’s capabilities depend on other

modernization efforts, such as those involving information systems, and

will not be operational for a few years.

As noted earlier, small businesses are more likely than other segments of

the taxpayer population to have problems complying with the tax law due

to a combination of complex filing requirements and limited resources

available to meet those requirements. Through a new compliance strategy

and streamlined management structure, SB/SE hopes to increase

compliance and improve customer satisfaction.

Similar to IRS’ current organization, most of SB/SE’s resources are to be

allocated to the Compliance unit. Unlike the current organization,

however, SB/SE intends to implement a more balanced approach to

improving compliance by blending traditional enforcement activities with

education and outreach. For example, IRS’ current collection process is a

“one-size fits all” approach that treats all taxpayers alike. Under its new

strategy, IRS intends to segment small businesses with collection issues by

risk of nonpayment. A low-risk small business might receive a blend of

education and enforcement activities, but a high-risk small business might

receive aggressive enforcement action. Specific details about this new riskbased strategy, such as the criteria to be used in assessing risk, have yet to

be developed.

To enhance this blend of enforcement and outreach, the operating division

is to implement an information-sharing process between the Compliance

and Taxpayer Education and Communication units. According to IRS,

 

16 The five account management centers are to be co-located with five compliance centers that also are

to be dedicated to SB/SE. Those co-located centers are to be in Brookhaven, NY; Philadelphia, PA;

Cincinnati, OH; Memphis, TN; and Ogden, UT.

17 Account management activities include responding to customer inquires; solving customer problems;

providing options to settle accounts; and handling issues received through phone calls,

correspondence, and electronic mail.

Compliance
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Page 20 GAO/GGD-00-166 Small Businesses

information gained during compliance activities should help direct

education and outreach initiatives, which could help reduce the number of

problems small businesses experience before returns are filed.

According to IRS, the Compliance unit will have fewer layers of

management, which will better facilitate communication and free up

personnel to increase support for other activities, including taxpayer

education. For example, the unit is to have one management position—

territory manager—that is to be responsible for the scope of work covered

by three positions in IRS’ current compliance function—district director,

division chief, and branch chief. Also, the Compliance unit’s management

structure is to be cross-functional, requiring knowledge of examination

and collection procedures.

IRS’ efforts to create a more taxpayer-focused organization with a

streamlined management structure and greater end-to-end accountability

are a step in the right direction. However, formidable challenges remain.

SB/SE’s ability to effectively focus on the needs and problems of small

businesses may not be easy given the diversity of that segment of the

taxpayer population and the need to find an effective way to serve

taxpayers who migrate between operating divisions from year to year. The

operating division also faces formidable challenges in its ability to deliver

new services and programs because effective delivery depends on

drastically improved information systems and a substantial shift in

employee skills. Lastly, the operating division, and IRS as a whole, will be

challenged to develop an integrated performance management system that

will lead to changes in organizational and employee behavior.

Through reorganization, IRS intends to improve its customer focus.

Although creation of SB/SE should facilitate a sharper focus on the needs

and problems of small businesses than is possible under the current

organization, the division will be challenged by the need to (1) serve a

diverse population and (2) devise effective procedures for dealing with

taxpayers who migrate between operating divisions.

SB/SE’s ability to provide focused service will be complicated by the

diversity of the population it is to serve. According to IRS, the

approximately 40 million taxpayers to be served by SB/SE include about

6.2 million small partnerships and corporations; 19.3 million partially or

fully self-employed individuals;18 13 million individual filers with

 

18 According to IRS, as many as one-half of self-employed filers receive the vast majority of their

income from wages, not business-related enterprises, and are considered “incidental” business filers.

Formidable Challenges

Confront SB/SE and IRS

Challenges to Operating

Division’s Customer Focus
B-282856

Page 21 GAO/GGD-00-166 Small Businesses

supplemental income or business expenses; and 1.2 million nonsmall

business taxpayers who are considered specialty tax filers.19 This size and

diversity compares with (1) the Wage and Investment Income Operating

Division, which is to serve a larger but less diverse customer segment

(about 116 million taxpayers who have only wage and investment income);

and (2) the Large and Mid-size Business Operating Division, which is to

serve a smaller and less diverse population (about 210,000 corporations

and partnerships with assets of more than $5 million).

Further evidence of the diversity of the small business population can be

seen in figure 5, which is a profile of the small businesses in our study

population. As the figure shows, that population involved a mixture of

business structures and industries and varied widely in terms of number of

employees and gross receipts.

 

19 Specialty tax filers include individual taxpayers with international tax returns and filers of fiduciary,

estate, and gift tax returns.
B-282856

Page 22 GAO/GGD-00-166 Small Businesses

Note: N = 398,105.

Source: Responses to GAO questionnaire.

The diversity of the small business population will require that SB/SE staff

specialize in a wide range of tax issues and deal with a wide range of

taxpayer needs. For example, the needs of wage earners who also operate

small, one-person businesses from their homes can vary significantly from

Figure 5: Profile of Small Business

Study Population
B-282856

Page 23 GAO/GGD-00-166 Small Businesses

corporations that employ 100 persons and have gross receipts in excess of

$1 million.

Besides handling the workload for its own diverse population, SB/SE is

also expected do work for other operating divisions. For example, SB/SE is

to do certain types of audit and collection work (cases involving complex

examination issues or requiring enforcement action) for the Wage and

Investment Income Operating Division. These additional responsibilities

could stretch the capabilities of management and staff in SB/SE and dilute

its customer focus.

Taxpayer migration also poses a challenge to the customer focus intended

by the reorganization. Migration refers to scenarios under which a

taxpayer might qualify as a small business one year but not the next, or

vice versa. These scenarios could cause taxpayers to change operating

divisions from year to year under the new organization. For example,

according to IRS data, about 2.2 million individuals who had filed for tax

year 1995 as pure wage earners (i.e., the kind of taxpayer for which the

Wage and Investment Income Division is to be responsible) filed for tax

year 1996 as sole proprietors (i.e., SB/SE-type taxpayers); and 1.7 million

individuals who had filed as sole proprietors for tax year 1995 filed as pure

wage earners for tax year 1996. Similarly, a corporation or partnership

could have more than $5 million in assets one year (and thus be part of the

population to be served by the Large and Mid-size Business Operating

Division) and less than $5 million in assets the following year (which

would make it part of SB/SE).

IRS acknowledges that taxpayer migration could present account

management problems for SB/SE and other operating divisions.

Specifically, this issue could lead to disparate treatment of taxpayers and

hamper IRS’ ability to provide end-to-end accountability because the

responsibility for managing a migrating taxpayer’s account could shift

from one operating division to another. IRS is working on plans to put

processes in place to allow for greater interaction between the account

management units within the operating divisions to properly manage and

serve migrating taxpayers.

SB/SE will also be challenged to deliver the various new programs and

services discussed earlier. In general, the division’s challenges are a result

of (1) antiquated computer systems and (2) a shortage of staff with needed

skills.

Challenges to Operating

Division’s Ability to Deliver New

Programs and Services
B-282856

Page 24 GAO/GGD-00-166 Small Businesses

IRS’ antiquated computer systems have long hindered agency efforts to

manage operations and serve taxpayers. IRS clearly documented the

significance of this challenge in a publication entitled Modernizing

America’s Tax Agency.20 Among the many statements in that document

relating to information systems are the following:

“[IRS] has a very special problem that is a serious, on-going risk and a fundamental barrier

to achieving its strategic goals. This problem is that the core data systems that keep records

on taxpayers’ tax accounts are fundamentally deficient.”

“Because of the delays in updating files and the lack of synchronization of data among

different systems, IRS employees frequently have inconsistent and out-of-date data about a

given taxpayer.”

These data problems contribute to the kind of issues raised in previously

cited quotes from respondents to our survey who complained about

getting multiple notices from IRS and about IRS employees who do not

seem helpful or knowledgeable.

IRS has struggled with systems modernization for years, and we have

made numerous recommendations to correct management and technical

weaknesses that jeopardized the modernization process.21 Although IRS

has made progress in addressing our recommendations, it has yet to fully

implement them. More specifically, IRS needs to fully implement key

controls that are needed to effectively guide and constrain modernization

initiatives. These controls include (1) completing and implementing a

blueprint for modernization; (2) implementing a “systems life cycle”

process, including development of business cases, to manage system

investments; and (3) establishing a fully operational management structure

to oversee systems modernization.

Improvements to IRS’ information systems are critical to SB/SE’s overall

success. IRS acknowledges, for example, that small business taxpayer

education and communication initiatives depend on substantial

investments in computer hardware and software and that major systems

changes will be required to support a risk-based compliance strategy.

 

20 IRS Publication 3349, revised January 2000.

21 Tax Systems Modernization: Management and Technical Weaknesses Must Be Corrected If

Modernization Is To Succeed (GAO/AIMD-95-156, July 26, 1995) and Tax Systems Modernization:

Blueprint Is a Good Start But Not Yet Sufficiently Complete to Build or Acquire Systems

(GAO/AIMD/GGD-98-54, Feb. 24, 1998).
B-282856

Page 25 GAO/GGD-00-166 Small Businesses

A shortage of staff with needed skills can also adversely affect SB/SE’s

ability to deliver new taxpayer education programs and services.

According to IRS, the Taxpayer Education and Communication unit will

require substantial resources, including staff with a blend of existing and

new skills. However, the demand for employees possessing the necessary

skills to staff the unit exceeds the current supply. For example, SB/SE

intends to improve taxpayer education and assistance through research

and analysis of taxpayer characteristics and behavior. However, according

to IRS, it does not have enough employees who possess the requisite skills,

such as market research, forecasting, and trend analysis. Such limitations

could delay SB/SE’s ability to develop and deliver specialized education

and assistance to small businesses.

A coherent organization and management structure dedicated to small

businesses will not significantly improve service to taxpayers without a

performance management system that aligns employee, program, and

strategic performance measures and creates incentives for behavior that

supports agency goals. IRS has made some headway in this area as it

develops a new set of performance measures balancing customer

satisfaction, employee satisfaction, and business results and updates its

employee evaluation system.

Although IRS has clearly made progress in implementing new performance

measures, it is missing a key indicator for voluntary compliance with the

tax laws. Such a measure is essential for a number of reasons. Regularly

measuring voluntary compliance is important to gauge whether IRS is

accomplishing a key aspect of its mission. Also, the information about

taxpayers that would be generated in measuring voluntary compliance may

help IRS identify the characteristics of taxpayers who have difficulty

understanding and meeting their tax responsibilities. Finally, the data IRS

would develop as part of any voluntary compliance measurement effort

may allow IRS to better direct its enforcement resources to those

taxpayers who willfully violate the tax laws, thus reducing the burden on

compliant taxpayers. The absence of a measure of voluntary compliance

could hinder SB/SE more than other operating divisions because,

according to IRS, the SB/SE population generally has a greater potential

for noncompliance. IRS recognizes that it needs a reliable and meaningful

measure of voluntary compliance and is working with a contractor to

determine how to measure compliance with the least burden on taxpayers.

However, that effort is still in its early stages.

A second critical aspect of performance management is an employee

evaluation system that reflects the agency’s mission. As mentioned earlier,

Operating Division and IRS Will

Be Challenged to Develop and

Implement a Performance

Management System
B-282856

Page 26 GAO/GGD-00-166 Small Businesses

for example, SB/SE intends to refocus its compliance capabilities to

provide a mix of education and outreach along with an integration of its

traditional enforcement activities, examination and collection. IRS

recognizes that a successful blend of customer service and integrated

enforcement activities requires not only a substantial shift in employees’

skills but also a significant change in employee attitude and behavior. IRS

also recognizes that to achieve this shift, employees must have a clearer

line of sight between their day-to-day activities, their resulting

performance evaluations, and the agency’s broader goals. IRS is exploring

several different approaches for revising its employee evaluation system to

make the relationship between employee performance and agency

performance more transparent.

IRS’ new organizational structure is a positive step toward improving IRS’

ability to effectively and efficiently administer the tax system for small

businesses. The new organization may not be able to do much to reduce

the tax law complexity facing small businesses, but it should be able to

help businesses better deal with those complexities. With the

establishment of SB/SE, IRS will have an organization that can focus on

addressing the factors that make small businesses more likely to be

noncompliant and on correcting those factors that have aroused the kind

of negative feelings about IRS that some respondents expressed in our

survey.

Any improvement in these areas will depend on the processes and

procedures the new organization adopts and how effectively they are

implemented. Some of the planned changes, such as those related to

partnering, may be fairly easy to implement. However, for the more

substantive changes, such as risk-based compliance, to happen, SB/SE, and

indeed all of IRS, will have to overcome several challenges. Because some

of those challenges, especially the need to modernize IRS’ computer

systems, will require a significant amount of sustained effort, it may be

several years before those more substantive changes are fully

implemented.

We requested comments on a draft of this report from IRS. We obtained

IRS’ written comments in a July 18, 2000, letter from the Commissioner of

Internal Revenue (see app. III).

The Commissioner said that IRS was committed to implementing a

customer-focused organization that will benefit all taxpayers and that our

report would help IRS improve its products and services for small

businesses.

Conclusions

Agency Comments and

Our Evaluation
B-282856

Page 27 GAO/GGD-00-166 Small Businesses

The Commissioner cited several actions, in addition to those mentioned in

our report, that IRS is taking to improve its products and services. The

cited actions generally involved changes to simplify certain small businessrelated publications and steps to improve telephone service for small

businesses and practitioners. The Commissioner noted, for example, that

IRS (1) streamlined its Tax Guide for Small Business by removing

information pertaining to larger businesses and (2) would begin

accumulating telephone service customer satisfaction data from SB/SE

customers, which is expected to result in improved telephone service.

As agreed with your office, unless you publicly release its contents earlier,

we plan no further distribution of this report until 30 days from the date of

this letter. At that time, we will send copies to Senator John Kerry,

Ranking Minority Member of your Committee; Senator William V. Roth, Jr.,

Chairman, and Senator Daniel P. Moynihan, Ranking Minority Member,

Senate Committee on Finance; and Representative Bill Archer, Chairman,

and Representative Charles B. Rangel, Ranking Minority Member, House

Committee on Ways and Means. Copies will also be sent to the Honorable

Lawrence H. Summers, Secretary of the Treasury; the Honorable Charles

O. Rossotti, Commissioner of Internal Revenue; and the Honorable Jacob

Lew, Director, Office of Management and Budget. Copies will be made

available to others upon request.

If you or your staff have any questions concerning this report, please

contact me or David Attianese on (202) 512-9110. Key contributors to this

report are acknowledged in appendix IV.

Sincerely yours,

Cornelia M. Ashby

Associate Director, Tax Policy

 and Administration
Page 28 GAO/GGD-00-166 Small Businesses

Contents

1 Letter

30

Sample Selection Methodology 30

Response Rates 31

Sampling and Nonsampling Errors for Key Estimates

Used in the Report

32

Appendix I

Sampling and Data

Analysis Methodology

Appendix II 33

Final Results From

Survey of Small

Businesses

Appendix III 44

Comments from the

Internal Revenue

Service

Appendix IV 47

GAO Contacts and

Staff

Acknowledgments

Table 1: Non-IRS Sources of Tax Information 18

Table I.1: Strata for Small Business Study Population 31 Tables

Figure 1: Extent to Which Small Businesses Relied on

Practitioners to Understand Tax Issues

8

Figure 2: Awareness and Use of Selected IRS Services

Among Small Businesses

11

Figure 3: Reaction of Small Businesses to Selected

Interactions With IRS

13

Figure 4: Structure of IRS’ New Organization 16

Figure 5: Profile of Small Business Study Population 22

Figures
Contents

Page 29 GAO/GGD-00-166 Small Businesses

Abbreviations

CPA certified public accountant

IRS Internal Revenue Service

NFIB National Federation of Independent Businesses

SB/SE Small Business/Self-Employed Operating Division
Appendix I

Sampling and Data Analysis Methodology

Page 30 GAO/GGD-00-166 Small Businesses

To identify the problems small businesses have encountered in the past in

dealing with IRS, we identified a population of small businesses from the

membership list of the National Federation of Independent Businesses

(NFIB), a major national organization representing this population.1

An ideal survey population would have been all small businesses in the

country. In the absence of such a database or list, we identified a number

of national organizations that represent small businesses. We chose NFIB’s

membership list because it was the largest and included members from a

wide range of business sectors. NFIB is an organization of businesses that

are not publicly held. Although not exclusively an organization of small

businesses, NFIB officials told us that nearly all members of NFIB are

small businesses. NFIB’s membership list is actively used by the

organization and is updated frequently.

We reached a general consensus regarding this choice with IRS’ Executive

Director for Small Business Modernization, the Small Business

Administration’s Office of Advocacy, and a number of other membership

organizations representing small businesses. We included a screener

question on the questionnaire asking respondents about their businesses’

total assets, and we did not include responses from businesses that had

$5 million or more in total assets.

The mailing list of NFIB members that we used contained 398,105

businesses nationwide. In constructing this list, we excluded some

members because they were either (1) a call center company that was

excluded from NFIB mailings, (2) a company that did not want personal

names and/or company names to appear on mailing pieces, (3) a company

with a negative zip code number in the database, (4) a company that

requested to not receive any mail as a result of NFIB membership, or (5) a

so-called “decoy” company whose presence on NFIB’s mailing list was

only to detect unauthorized use of the mailing list. The mailing list we used

to select the sample was current as of September 11, 1999.

We selected a stratified random sample of 1,000 businesses from our list of

398,105. The strata were defined by whether the business was structured

as a sole proprietorship or other type of structure. These strata were

selected because we wanted to ensure that sole proprietorships were

adequately represented in our study population. The strata population and

number of businesses selected are shown in table I.1.

 

1

 As defined previously, the term “small business” includes self-employed individuals (also known as

sole proprietorships).

Sample Selection

Methodology
Appendix I

Sampling and Data Analysis Methodology

Page 31 GAO/GGD-00-166 Small Businesses

Stratum Population

Number of businesses

selected

Sole proprietorships 151,908 500

All other businesses 246,197 500

Totals 398,105 1,000

Source: GAO analysis of NFIB membership list.

Our questionnaire asked for background information about the business,

such as the number of employees, the type of industry the business was

involved in, and whether the respondent typically prepared the federal tax

returns for the business or hired a tax preparer or accountant to do it. It

asked about what IRS and non-IRS services and resources the respondent

had used; and it asked the respondent to rate his or her satisfaction with

various products, services, and functions provided by IRS.

We sought reactions from officials at IRS, the Small Business

Administration, and NFIB to a draft of the questionnaire. We then

pretested it with two small business owners who completed the

questionnaire and shared their opinions and suggestions. The

questionnaire took each pretest respondent about 15 minutes to complete.

A copy of the final questionnaire and the survey responses are shown in

appendix II.

To encourage candid responses, the questionnaire was completely

anonymous, with no way for us to identify the answers of any business

individually. A postcard was included with each questionnaire, for

respondents to return separately to let us know that they had mailed back

their questionnaires. That enabled us to exclude those who had already

responded from follow-up mailings.

In addition, a letter from NFIB, encouraging members to respond,

accompanied the questionnaire and our cover letter. We conducted the

initial mailout on September 30, 1999. We sent a follow-up mailing to

nonrespondents on October 28, 1999, and sent a final mailing on December

2, 1999.

We received 548 usable responses to our questionnaire, or a response rate

of 55 percent. Five other questionnaires were returned to us as not

deliverable, and another five questionnaires were received but not used

because the respondents said that they had $5 million or more in total

assets, which exceeded our criteria for a small business.

Table I.1: Strata for Small Business

Study Population

Questionnaire Design

Response Rates
Appendix I

Sampling and Data Analysis Methodology

Page 32 GAO/GGD-00-166 Small Businesses

Because our survey results come from samples, all results are estimates

that are subject to sampling errors. We calculated sampling errors for all of

the survey results presented in this report. These sampling errors measure

the extent to which samples of these sizes and structure can be expected

to differ from their total populations. Each of the sample estimates is

surrounded by a 95-percent confidence interval. This interval indicates that

we are 95-percent confident that the results for the total population fall

within this interval. Unless otherwise noted, the 95-percent confidence

intervals for proportions do not exceed 10 percentage points. All numeric

estimates other than proportions have sampling errors smaller than 10

percent of the value of those estimates, unless otherwise noted.

In addition to the reported sampling errors, the practical difficulties of

conducting any survey may introduce other types of errors, commonly

referred to as nonsampling errors. For example, differences in how a

particular question is interpreted, in the sources of information that are

available, or in the types of files not available introduce unwanted

variability into the survey results. We included steps in our audit to

minimize such nonsampling errors. For example, we carefully pretested

the survey instrument and discussed our survey results with cognizant IRS

officials at the National Office and at field locations we visited and in

discussions with various small business representatives.

Sampling and

Nonsampling Errors

for Key Estimates

Used in the Report
Appendix II

Final Results From Survey of Small

Businesses

Page 33 GAO/GGD-00-166 Small Businesses
Appendix II

Final Results From Survey of Small Businesses

Page 34 GAO/GGD-00-166 Small Businesses
Appendix II

Final Results From Survey of Small Businesses

Page 35 GAO/GGD-00-166 Small Businesses
Appendix II

Final Results From Survey of Small Businesses

Page 36 GAO/GGD-00-166 Small Businesses
Appendix II

Final Results From Survey of Small Businesses

Page 37 GAO/GGD-00-166 Small Businesses
Appendix II

Final Results From Survey of Small Businesses

Page 38 GAO/GGD-00-166 Small Businesses
Appendix II

Final Results From Survey of Small Businesses

Page 39 GAO/GGD-00-166 Small Businesses
Appendix II

Final Results From Survey of Small Businesses

Page 40 GAO/GGD-00-166 Small Businesses
Appendix II

Final Results From Survey of Small Businesses

Page 41 GAO/GGD-00-166 Small Businesses
Appendix II

Final Results From Survey of Small Businesses

Page 42 GAO/GGD-00-166 Small Businesses
Appendix II

Final Results From Survey of Small Businesses

Page 43 GAO/GGD-00-166 Small Businesses
Appendix III

Comments from the Internal Revenue Service

Page 44 GAO/GGD-00-166 Small Businesses
Appendix III

Comments from the Internal Revenue Service

Page 45 GAO/GGD-00-166 Small Businesses
Appendix III

Comments from the Internal Revenue Service

Page 46 GAO/GGD-00-166 Small Businesses
Appendix IV

GAO Contacts and Staff Acknowledgments

Page 47 GAO/GGD-00-166 Small Businesses

Cornelia M. Ashby (202) 512-9110

David J. Attianese (202) 512-9110

In addition to those named above, Kirk Boyer, Stuart Kaufman, Daniel

Lynch, Yong Meador, Anne Rhodes-Kline, and Samuel Scrutchins made key

contributions to this report.

GAO Contacts

Acknowledgments
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