GAO-05-319R IRS Revenue Management Report 

United States Government Accountability Office

Washington, DC 20548 

March 10, 2005 

John M. Dalrymple 

Deputy Commissioner for Operations Support 

Internal Revenue Service 

Subject: Management Report: Review of Controls over Safeguarding Taxpayer 

Receipts and Information at the Brookhaven Service Center Campus

Dear Mr. Dalrymple: 

This report responds to your request that, in conjunction with our audit of the 

Internal Revenue Service’s (IRS) fiscal year 2004 financial statements,1 we review the 

agency’s procedures for handling and processing receipts and taxpayer information 

at the Brookhaven service center campus. As a result of the increased percentage of 

taxpayers filing returns electronically, IRS designed a detailed business plan to 

reduce the number of service center campuses that process paper returns. In fiscal 

year 2004, Brookhaven became the first service center campus to downsize its 

submission processing function, leading to changes in its operations and a significant 

reduction in the volume of taxpayer receipts and information processed.2

 You 

requested this review in light of these significant changes in operations and IRS’s 

desire to benefit from the Brookhaven experience in planning for future submission 

processing rampdowns.3

 Specifically, you asked us to (1) review the policies and 

procedures IRS developed to safeguard and process taxpayer receipts and 

information at the modified Brookhaven operation and (2) offer recommendations, if 

any, for improving internal controls at Brookhaven and at other submission 

processing centers that will undergo future rampdowns. To accommodate your 

request, we agreed to add a review of the mail control function at the Brookhaven 

service center campus to our tests of internal controls conducted as part of our audit 

of IRS’s fiscal year 2004 financial statements. 

 

As you are aware, we have performed extensive work in reviewing internal controls 

designed to safeguard taxpayer receipts and information as part of our annual 

 

1

GAO, Financial Audit: IRS’s Fiscal Years 2004 and 2003 Financial Statements, GAO-05-103 

(Washington, D.C.: Nov. 10, 2004). 2

Submission processing is the data processing arm of IRS. These units process paper and electronic 

submissions at IRS service center campuses. This includes depositing tax payments, correcting errors, 

and forwarding data to IRS’s computing centers for analysis and posting to taxpayer accounts. 

3

In this report, the term “rampdown” is used to refer to IRS’s significant reduction of its submission 

processing functions at selected service center campuses. 
Page 2 GAO-05-319R IRS Revenue Management Report 

financial audits of IRS.4 In performing this work, we have come to recognize the 

significance and importance of the submission processing function to IRS and the 

potential for loss, theft, or misuse of taxpayer receipts and information if controls are 

not properly designed and effectively implemented. Our audits have identified 

weaknesses in internal controls over the safeguarding of taxpayer receipts and 

information related to submission processing activities at IRS’s service center 

campuses, lockbox banks,5 and field offices. In reviewing the Brookhaven rampdown 

procedures, we considered the internal control weaknesses previously found at other 

service center campuses. 

We performed most of our work from May 2004 through October 2004 as part of our 

audits of IRS’s fiscal years 2004 and 2003 financial statements, with some additional 

follow-up work completed in January 2005. 6 We designed our tests and inquiries 

based on results and findings from our previous years’ audits and financial 

management-related reviews, taking into consideration differences that may occur 

during a nonpeak tax filing season and the nature of Brookhaven’s ramped down 

operations. We conducted our work in accordance with U.S. generally accepted 

government auditing standards. Additional details on our scope and methodology are 

included in our fiscal year 2004 financial statement audit report.7

Results in Brief 

We found that IRS completed the rampdown at Brookhaven without any significant 

disruptions in service. However, we did identify several areas where improvements 

could be made to internal controls at the Brookhaven service center campus residual 

mail processing unit, as well as to the process for estimating mail volumes. These 

issues are also relevant to IRS as it proceeds in ramping down future submission 

processing functions. 

Specifically, we found the following: 

• IRS developed standard operating procedures for employees processing incoming 

mail at Brookhaven during the rampdown. However, we found that these 

procedures did not include detailed instructions for (1) tracking taxpayer receipts 

and information forwarded to other service center campuses for further 

processing and (2) handling cash receipts found during the extraction process. 

The absence of these instructions increases the risk that employees with 

significant internal control responsibilities over high-risk and vulnerable assets 

are not aware of the correct procedures to be followed in safeguarding and 

 

4

GAO, Internal Revenue Service: Status of Recommendations from Financial Audits and Related 

Financial Management Reports, GAO-04-523 (Washington, D.C.: Apr. 28, 2004). 5

Lockbox banks are financial institutions designated as depositories and financial agents of the U.S. 

government to perform certain financial services, including processing tax documents, depositing the 

receipts, and then forwarding the documents and data to IRS’s service center campuses, which update 

taxpayers’ accounts. 

6

As agreed, we visited Brookhaven in May 2004 after the peak tax filing season, which primarily occurs 

from January 1 through April 15 of each year when most individual tax returns are filed. 

7

GAO-05-103. 
Page 3 GAO-05-319R IRS Revenue Management Report 

processing taxpayer receipts and information, thereby increasing the risk of their 

theft, loss, or misuse. 

• Staff at the Brookhaven location did not always follow the required procedures to 

safeguard taxpayer receipts and information in its facilities. We found that 

(1) access rights allowed to visitors were not always appropriately restricted; 

(2) trash, which included taxpayer information, was not always sufficiently 

secured; and (3) candling8

 was not always properly performed. The lack of 

adherence to IRS’s procedures increases the risk of theft, loss, or misuse of 

taxpayer receipts and information. 

• IRS did not have a documented methodology for estimating post-rampdown mail 

volumes at service center campuses selected for rampdowns. The lack of a 

documented methodology increases the risk that adequate mail volume 

information will not be gathered, maintained, and appropriately considered as 

estimates are prepared to assist IRS management in making decisions related to 

sites selected for future rampdowns and assessing their ultimate success. 

This report offers three recommendations to assist IRS with strengthening controls 

over the safeguarding of taxpayer receipts and information and preparing for future 

rampdowns. In its comments, IRS agreed with our recommendations and described 

actions that it had taken or planned to take to address the issues described in this 

report. 

Scope and Methodology 

In conducting our review of the Brookhaven submission processing function, we did 

the following: 

• Visited the Brookhaven service center campus from May 24 through May 27, 2004, 

and observed mail operations over taxpayer receipts and information. 

• Conducted interviews with IRS and U.S. Treasury Inspector General for Tax 

Administration officials regarding the phaseout of the submission processing 

function. 

• Gathered and analyzed data outlining IRS’s planning and implementation 

processes for the Brookhaven rampdown. 

• Reviewed data covering fiscal year 2004 mail volumes, IRS’s summary of lessons 

learned from the rampdown, and strategies for ramping down future submission 

processing functions. 

 

8

Candling is a process used by IRS to determine if any contents remain in open envelopes. This is often 

achieved by passing the envelopes over a light source. 
Page 4 GAO-05-319R IRS Revenue Management Report 

Background 

On July 22, 1998, Congress enacted the IRS Restructuring and Reform Act of 1998 

(RRA 98)9

 to better balance IRS’s responsibility to collect taxes, protect the rights of 

taxpayers, and serve the public. Among other provisions, RRA 98 authorized IRS to 

encourage the use of its electronic tax administration programs by taxpayers to reach 

the goal of 80 percent of individual tax returns filed electronically by 2007. IRS has 

strongly encouraged taxpayers to file electronically and acted to facilitate and 

support this transition. Although IRS does not expect to achieve the goal set by RRA 

98, substantial progress has been made. From 1998 to 2004, the volume of paper 

returns decreased by 30 million returns—from 101 million in 1998 to 71 million in 

2004 (over 29 percent). IRS reported that during the 2004 filing season, 47 percent of 

individual tax returns were filed electronically. As part of its approach to 

administering and managing this change in taxpayer behavior, IRS developed and 

approved a detailed business plan to gradually reduce the number of its submission 

processing functions that process individual and business tax returns. The plan calls 

for the rampdown of a submission processing function every few years until this 

function remains at only four service center campuses (SCC). The pace of 

implementation depends on the public’s continued migration from paper to 

electronically filed returns. 

Prior to rampdown, Brookhaven performed functions generally similar to the other 9 

IRS SCCs in the processing of taxpayer receipts and information. All 10 SCCs also 

managed taxpayer accounts and compliance programs. The functions performed by 

SCCs included (1) opening, sorting, and extracting mail; (2) depositing payments; 

(3) posting data to IRS’s financial management systems; and (4) reconciling deposits 

to deposit information maintained at the Department of the Treasury’s Financial 

Management Service. In connection with the Brookhaven rampdown, IRS instructed 

taxpayers and tax preparers who previously submitted their returns to the 

Brookhaven SCC to instead send their returns, payments, or both to other specifically 

designated locations. 

Despite IRS’s instructions designating other locations to which returns were to be 

sent, some taxpayers continue to mail tax returns and receipts to the Brookhaven 

location. Mail arriving at the Brookhaven SCC, including some taxpayer returns, 

payments, correspondence, notices, and mail returned to IRS as undeliverable, is now 

handled by a newly created unit within Brookhaven, the Accounts Management Mail 

Unit. This unit is tasked with the goal of timely performing the initial mail processing, 

including extracting, dating and recording, sorting, and candling. The receipts and tax 

returns are then forwarded overnight to either the Andover or Cincinnati SCCs for 

further processing, depending on the type of return involved.10

 

 

9

IRS Restructuring and Reform Act of 1998, Pub. L. No. 105-206, 112 Stat. 685 (July 22, 1998). 

10Individual returns and payments are forwarded to the Andover SCC and business returns and 

payments are forwarded to the Cincinnati SCC. 
Page 5 GAO-05-319R IRS Revenue Management Report 

No Major Disruptions in Brookhaven Operations during Its Submission 

Processing Rampdown 

During fiscal year 2004, IRS implemented its rampdown of the Brookhaven SCC 

submission processing function with no major disruptions in service. As part of this 

success, the Brookhaven SCC exceeded its goal of sending taxpayer receipts and 

returns for further processing to either of the two other designated SCCs within 3 to 5 

workdays from time of receipt in Brookhaven, generally accomplishing this task 

within 48 hours. IRS’s ability to successfully realize its rampdown is attributable in 

part to (1) early planning, which began as far back as 1998; (2) initiatives that the 

personnel office undertook to ensure minimum impact to the taxpayers and IRS’s 

employees; and (3) involvement of the necessary business divisions, offices, units, 

and managers from its functional areas, including operations, communications, 

infrastructure (i.e., equipment and real estate), and personnel. 

IRS’s planning efforts were critical because the rampdown had a dramatic impact on 

Brookhaven SCC operations and its personnel. For example, the rampdown 

necessitated the agency’s first reduction in force,11 affecting more than 2,700 

employees previously assigned to the campus’s submission processing function. Of 

those employees, 664 were actually laid off. The remaining employees were 

reassigned to other jobs, took advantage of voluntary retirement or separation 

incentives, or resigned from their jobs. As of January 2005, 127 employees were 

assigned to processing incoming mail in the Brookhaven Accounts Management Mail 

Unit. 

IRS continues to plan for future rampdowns12 through the following strategies: 

(1) gaining consensus from its managers and employees on how to approach future 

rampdowns, (2) identifying areas of improvement based on the implementation of the 

Brookhaven SCC rampdown, (3) documenting and evaluating common consolidating 

themes and lessons learned, and (4) incorporating those lessons learned into future 

rampdown implementation plans. As IRS proceeds with the implementation of its 

detailed business plan to reduce the number of SCCs that process paper returns, it is 

critical that effective internal controls are maintained to deal with the unique risks 

entailed in the changing submission processing environment. 

Certain Procedures Could Be Strengthened as IRS Pursues Future 

Rampdowns 

While we want to emphasize that IRS’s rampdown of the Brookhaven submission 

processing function was achieved with no major service disruptions, our review 

identified certain matters that should be addressed to provide for better safeguarding 

of taxpayer receipts and information and better efficiency in the processing and 

monitoring of residual returns and receipts at Brookhaven and at future rampdown 

locations. Specifically, we identified three areas where IRS’s procedures could be 

strengthened: (1) instructions and guidance to staff processing mail, (2) adherence to 

 

11In the federal government, layoffs are called reductions in force. 

12IRS plans to ramp down the Memphis and Philadelphia submission processing functions during fiscal 

years 2005 and 2007, respectively. 
Page 6 GAO-05-319R IRS Revenue Management Report 

existing management controls, and (3) procedures for estimating future mail volume 

data. Each of these areas is relevant to operations at other SCCs and to IRS’s success 

as it proceeds with future rampdowns. 

Instructions and Guidance to Staff Processing Mail 

Recognizing the change required in the Brookhaven Accounts Management Mail Unit 

operations to process residual returns and receipts received during and after the 

rampdown, IRS developed specific standard operating procedures (SOP) to instruct 

and guide mail room staff. We noted that the SOPs could be strengthened by 

including specific instructions for (1) monitoring document transmittals after receipts 

and tax returns were forwarded to another SCC for final processing and 

(2) processing cash discovered during the extraction process. The absence of such 

instructions in the Brookhaven SOPs increases the risk that employees are not 

familiar with how to safeguard, process, and account for taxpayer receipts and 

information. We did note that instructions related to these two areas did exist in 

various sections of IRS’s Internal Revenue Manual (IRM)13 related to submission 

processing. However, the Brookhaven SOPs that were used to guide staff on a daily 

basis were silent on these tasks and did not contain a reference to these requirements 

in the IRM. 

Specifically, the SOP that outlines the procedures for preparing and mailing taxpayer 

receipts and information received between SCCs did not include instructions for the 

Accounts Management Mail Unit to timely verify that taxpayer receipts and 

information it had sent to other SCCs had been received in their entirety by the 

receiving SCCs. While we found instructions in the IRM addressing the monitoring of 

document transmittals used to mail items between IRS locations, these instructions 

were not available or referred to in the SOP. For instance, according to the Case 

Processing section of the IRM, IRS staff sending taxpayer receipts, returns, and 

information to SCCs are required to establish a control to ensure that the contents of 

packages were received. The IRM states that the receiving SCC must acknowledge 

receipt of package contents within 5 workdays. If no acknowledgment is received, 

the sender must initiate follow-up within 10 workdays. However, similar procedures 

for the Accounts Management Mail Unit staff were not outlined or mentioned in the 

SOP. Neither the IRM’s Case Processing section nor the SOP includes instructions for 

matching receipt acknowledgments to the original list of contents sent. Without these 

controls, the risk is increased that lost documents will not be promptly identified and 

affected taxpayers alerted timely. 

Illustrating this issue, during our site visit to the Brookhaven SCC, we found a basket 

in the Accounts Management Mail Unit that contained several weeks of 

acknowledged document transmittals from the Andover and Cincinnati SCCs that had 

not yet been matched to the original document transmittals. Without timely matching 

of the original copies of the document transmittals to the acknowledged ones, IRS 

management could not be timely assured that documents or packages (including 

 

13The IRM is IRS’s internal operating manual that sets forth the agency’s various operating polices and 

procedures. 
Page 7 GAO-05-319R IRS Revenue Management Report 

payments and returns) sent from the Brookhaven SCC actually reached their 

destinations. While Brookhaven staff stated that e-mails were received from the 

designated SCCs, the e-mails only acknowledged receipt of the packages and not the 

full extent of their contents. 

We also found that the SOPs did not include guidance on the processing of cash 

discovered during the extraction process. While the IRM contains detailed guidance 

for handling cash discovered during extraction, these instructions were not outlined 

or referred to in the SOP. Cash is not commonly used by taxpayers to make payments 

through the mail; however, we have observed cash payments submitted by taxpayers 

through the mail in prior audits. Consequently, because employees do not have clear 

guidance regarding the handling of cash, the risk is increased that such cash might be 

lost or misappropriated. 

During our review, we were informed that IRS plans to add the SOPs used by the 

Brookhaven Accounts Management Mail Unit to its IRM. The IRM will then be the 

general guide used for all other Accounts Management Mail Unit operations created 

as IRS continues with its plans for future submission processing consolidations. 

Adherence to Existing Management Controls 

During our visit to Brookhaven, we tested selected controls intended to safeguard 

taxpayer receipts and information. As agreed with IRS, our visit took place in May 

2004, a nonpeak period during which mail volume was lower and less processing was 

observed. Nonetheless, we found three instances where IRS employees did not 

adhere to the policies and procedures IRS currently has in place. 

 

• IRS requires that individuals inside any restricted area wear badges indicating 

access was granted. Such badges are to be worn only while in these areas and are 

required to be relinquished upon departure. However, after leaving a secured area, 

we were mistakenly given other badges with access rights to secured areas. 

• According to IRS standards, taxpayer data and related information no longer 

needed must be destroyed through a secure process such as shredding. While 

these items are awaiting destruction, IRS must protect the items from improper 

disclosure. However, we observed sensitive waste containing taxpayer 

information, such as undeliverable mail, computer screen printouts, and photo 

copies of incorrect document transmittals, stored on a loading dock in an 

unlocked container for periods of up to 2 weeks prior to disposal.14 While the 

loading dock was within a secured perimeter, employees, contractors, and visitors 

allowed in this area could have gained unauthorized access to this sensitive 

information. 

 

14IRS officials told us that pickups for these items are normally scheduled on a biweekly basis. 
Page 8 GAO-05-319R IRS Revenue Management Report 

• To prevent the accidental destruction of taxpayer receipts and information, IRS 

requires that emptied envelopes be candled twice before destruction to ascertain 

that all contents were removed. However, we observed one IRS employee who did 

not run the envelopes over the light source to complete the first candling. 

Although the lack of adherence to these policies and procedures created no major 

disruption in service or hindrance to IRS’s processing of mail received at the 

Brookhaven SCC, it increases the risk that taxpayer receipts and information will be 

unnecessarily exposed to potential loss, theft, or misuse. 

Procedures for Estimating Mail Volume Data 

IRS’s plan to ramp down its submission processing function is in direct response to 

the continuing decline in the volume of paper returns and receipts filed as taxpayers 

increasingly migrate to electronic filing. In effecting a rampdown at a specific SCC, 

volume of incoming hard-copy returns and receipts should normally decline 

dramatically over a short period of time as taxpayers are instructed to mail these 

returns and receipts to other locations. The rapid reduction in the volume of this type 

of mail inevitably requires significant changes in operating procedures and staffing 

levels. Detailed procedures documenting how to accumulate and utilize mail volume 

data are thus necessary to better enable IRS to estimate post-rampdown volume and 

measure the rampdown’s success. However, during our review, we did not find a 

documented methodology for estimating mail volumes that was tailored to 

encompass the dramatic changes in mail volume precipitated by a rampdown. 

Each year, IRS develops an annual plan that estimates the numbers and types of 

returns and receipts to be filed at each SCC during the upcoming tax filing season. 

This process considers such factors as prior years’ experience and processing, 

legislative, and budget changes. These estimates are used to assist IRS in determining 

the staffing needs of each SCC during routine operations when mail volume levels are 

relatively stable. However, this process is not designed to provide for the 

dramatically lower mail volumes expected in a rampdown. For example, according to 

IRS, during fiscal year 2002, Brookhaven processed about 26.8 million pieces of mail. 

In contrast, during fiscal year 2004, Brookhaven processed about 3.4 million pieces of 

mail, a decrease of over 87 percent from its pre-rampdown level. 

In reviewing the mail volume data maintained at the Brookhaven SCC after its 

rampdown, which included estimates and actual pieces of mail received, we found 

that staff were not provided with a methodology to assist them in compiling 

Brookhaven’s post-rampdown mail volume estimates. The lack of a documented 

methodology for estimating mail volume data at SCCs selected for a rampdown could 

affect IRS’s ability to develop sound and reliable mail volume estimates that can be 

used as a tool to assist in implementing and assessing the success of future 

rampdowns. This increases the risk that IRS management will not have reliable data 

available to effectively manage its resources during and after each rampdown or to 

evaluate its success. 
Page 9 GAO-05-319R IRS Revenue Management Report 

Conclusions 

IRS succeeded in ramping down the submission processing function at the 

Brookhaven SCC without any major disruption of operations. The completion of such 

a significant restructuring of a large and complex operation like an SCC without 

major service disruptions is a notable accomplishment. Nonetheless, opportunities 

exist for IRS to enhance its internal controls over the safeguarding of hard-copy 

taxpayer receipts and information at Brookhaven and future rampdown locations. 

IRS will inevitably experience similarly significant changes in mail volume at other 

SCCs as it proceeds with implementing its detailed business plan. To maximize the 

benefit IRS realizes from its Brookhaven experience will require a systematic, 

documented approach to analyzing and utilizing mail volume information and 

effectively applying it to planning for and assessing the success of future rampdowns.

Recommendations for Executive Action 

To address the issues we have raised in this report to assist in both strengthening 

controls at the Brookhaven SCC and in the planning and implementation of future 

SCC rampdowns, we recommend that IRS do the following: 

• Revise the Accounts Management Mail Unit procedures, scheduled to be 

incorporated into the IRM, to include detailed instructions for (1) monitoring 

transshipped documents and (2) handling cash receipts found during 

extraction. Where adequate guidance exists elsewhere, IRS should include 

these through cross-references. 

• Enforce adherence to existing instructions on safeguarding taxpayer receipts 

and information, such as securing access and candling procedures, at SCCs 

selected for significant reductions in their submission processing functions. 

• Document a methodology for estimating anticipated rapid changes in mail 

volume at future SCCs selected for significant reductions in their submission 

processing functions, taking into consideration factors such as the prior 

rampdown experience at Brookhaven. 

Agency Comments 

We received written comments on a draft of this report from IRS’s Commissioner. In 

commenting on our draft report, IRS’s Commissioner agreed with our 

recommendations and described actions that the agency had taken or planned to take 

to improve the planning, procedures, and residual work processes associated with 

future rampdowns. The IRS Commissioner’s comments are reproduced in their 

entirety in the enclosure to this report. 
Page 10 GAO-05-319R IRS Revenue Management Report 

- - - - - 

This report contains recommendations to you. We would appreciate receiving a 

description and status of your corrective actions within 30 days of the date of this 

report. 

This report is intended for use by the management of IRS. We are sending copies to 

the Chairmen and Ranking Minority Members of the Senate Committee on 

Appropriations; Senate Committee on Finance; Senate Committee on Homeland 

Security and Governmental Affairs; Senate Committee on the Budget; Subcommittee 

on Transportation and Treasury and General Government, Senate Committee on 

Appropriations; Subcommittee on Taxation and IRS Oversight, Senate Committee on 

Finance; Subcommittee on Oversight of Government Management, the Federal 

Workforce, and the District of Columbia, Senate Committee on Homeland Security 

and Governmental Affairs; House Committee on Appropriations; House Committee 

on Ways and Means; House Committee on Government Reform; House Committee on 

the Budget; Subcommittee on Transportation, Treasury, and Housing and Urban 

Development, The Judiciary, District of Columbia, House Committee on 

Appropriations; Subcommittee on Government Management, Finance, and 

Accountability, House Committee on Government Reform; and Subcommittee on 

Oversight, House Committee on Ways and Means. In addition, we are sending copies 

of this report to the Chairman and Vice Chairman of the Joint Committee on 

Taxation, the Commissioner of Internal Revenue, the Director of the Office of 

Management and Budget, the Chairman of the IRS Oversight Board, and other 

interested parties. Copies will be made available to others upon request. In addition, 

the report is available at no charge on GAO’s Web site at http://www.gao.gov. 

We acknowledge and appreciate the cooperation and assistance provided by IRS 

officials and staff during our review. If you have any questions or need assistance in 

addressing these matters, please contact me at (202) 512-3406 or sebastians@gao.gov. 

Key contributors to this assignment were Charles Fox, Alain Dubois, John Sawyer, 

and Gary Wiggins. 

Sincerely yours, 

Steven J. Sebastian 

Director 

Financial Management and Assurance 

Enclosure 
Page 11 GAO-05-319R IRS Revenue Management Report 

Enclosure 

Comments from the Internal Revenue Service 
Page 12 GAO-05-319R IRS Revenue Management Report 

Enclosure 
Page 13 GAO-05-319R IRS Revenue Management Report 

Enclosure 

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