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entitled 'Management Report: Review of Controls over Safeguarding 
Taxpayer Receipts and Information at the Brookhaven Service Center 
Campus' which was released on March 11, 2005.

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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,[Footnote 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.[Footnote 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.[Footnote 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 financial audits of IRS.[Footnote 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,[Footnote 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.[Footnote 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.[Footnote 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 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) 
candling[Footnote 8] 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.

Background:

On July 22, 1998, Congress enacted the IRS Restructuring and Reform Act 
of 1998 (RRA 98)[Footnote 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.[Footnote 10]

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,[Footnote 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 rampdowns[Footnote 12] 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 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)[Footnote 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 
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.[Footnote 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.

* 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.

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.

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,

Signed by: 

Steven J. Sebastian:

Director:

Financial Management and Assurance:

Enclosure:

Comments from the Internal Revenue Service:

DEPARTMENT OF THE TREASURY: 
INTERNAL REVENUE SERVICE: 
COMMISSIONER:

WASHINGTON, D.C. 20224:

March 8, 2005:

Mr. Steven J. Sebastian:
Director, Financial Management and Assurance: 
U.S. Government Accountability Office:
441 G Street, N.W.: 
Washington, D.C. 20548:

Dear Mr. Sebastian:

I am responding to your draft report entitled "Management Report. 
Review of Controls over Safeguarding Taxpayer Receipts and Information 
at the Brookhaven Service Center Campus" (GAO-05-319R). Thank you for 
reviewing our procedures for handling and processing receipts and 
taxpayer information at the Brookhaven Campus. I believe the 
information in your report will assist us in our future ramp down 
efforts. I appreciate your recognition that we completed this major 
reduction to our submission processing function without disruption to 
the public. Accomplishing this ramp down involved intense planning and 
implementation efforts from executives, managers, and employees 
throughout the IRS organization. Efforts of this scope and complexity 
are truly Servicewide team endeavors.

While we are pleased with the successful ramp down, I agree that we 
could make improvements in the planning, procedures, and residual work 
processes. I agree with each of your recommendations. Responses to your 
specific recommendations are enclosed.

I appreciate your willingness to conduct this review at our request. I 
know that your thorough review will strengthen our future ramp down 
efforts. If you have any questions, please contact Floyd Williams, 
Director, Legislative Affairs, at (202) 622-3720.

Sincerely,

Signed by: 

Mark W. Everson:

Enclosure:

Recommendation for the Commissioner:

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.

Response:

In response to GAO's recommendations regarding transshipped documents 
and cash receipts, we have submitted a new Internal Revenue Manual 
(IRM) update that is scheduled for publication in December 2005. In the 
interim, we will continue using the Standard Operating Procedures that 
contain detailed information for document transmittals and the 
monitoring and control of cash receipts.

Recommendation for the Commissioner:

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.

Response:

During the GAO visit, there were three instances identified where IRS 
employees did not adhere to the policies and procedures in place for 
safeguarding taxpayer receipts and information. These involved: (1) 
incorrect badge issuance; (2) failure to properly secure taxpayer data 
and related information while awaiting destruction; and (3) inadequate 
candling operations. Management in Brookhaven is aware of the cited 
problems, and corrective action has been taken to ensure that 
applicable employees and managers are fully familiar with the correct 
procedures.

With regard to item (1), the employee was counseled at the time of the 
occurrence. A meeting was held with security clerks to review badge 
procedures. Inventories of badges are now performed after each shift. 
To correct item (2), action was taken to ensure that the classified 
waste trailer is kept locked when not in use. To address item (3), the 
employee was counseled at the time of observation. A meeting was held 
with all mail employees to review the candling procedures and reviews 
continue to be performed by management.

Recommendation for the Commissioner:

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 ramp down experience at Brookhaven.

Response:

GAO identified a lack of a documented methodology for estimating the 
mail volumes in Brookhaven after the closing of the Submission 
Processing (SP) operation at that site. A documented methodology will 
be needed in future consolidations to ensure that IRS has reliable data 
to effectively manage resources during and after the consolidation 
period.

Brookhaven was the first SP site to be closed. In the future, we will 
use the historical data from Brookhaven, and any other prior 
consolidations, to develop and document our methodology for estimating 
future mail volumes. 

[End of section]

(196024):

FOOTNOTES

[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.

[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.

[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.

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

[10] Individual returns and payments are forwarded to the Andover SCC 
and business returns and payments are forwarded to the Cincinnati SCC. 

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

[12] IRS plans to ramp down the Memphis and Philadelphia submission 
processing functions during fiscal years 2005 and 2007, respectively.

[13] The IRM is IRS's internal operating manual that sets forth the 
agency's various operating polices and procedures.

[14] IRS officials told us that pickups for these items are normally 
scheduled on a biweekly basis.