Opportunities Exist to Transition Taxpayers From Submitting Computer-Prepared Tax
Returns on Paper to E-Filing
March 2004
Reference
Number: 2004-40-076
This report has cleared the Treasury
Inspector General for Tax Administration disclosure review process and
information determined to be restricted from public release has been redacted
from this document.
March
31, 2004
MEMORANDUM FOR
DEPUTY COMMISSIONER FOR SERVICES AND ENFORCEMENT
DEPUTY COMMISSIONER FOR
OPERATIONS SUPPORT
FROM: Gordon C. Milbourn III /s/ Gordon C.
Milbourn III
Acting Deputy Inspector
General for Audit
SUBJECT: Final
Audit Report - Opportunities Exist to
Transition Taxpayers From Submitting
Computer-Prepared Tax Returns on Paper to E-Filing (Audit #
200340044)
This
report presents the results of our review of the Internal Revenue Service’s (IRS) efforts to reduce
the volume of tax returns prepared using computer software packages but
submitted to the IRS on paper instead of being electronically filed (e-filed).
The
IRS is the largest processor of information in the world. For Tax
Year (TY) 2001, 63 percent of all individual tax returns it processed were
filed on paper. However, it is the policy of the Congress
that paperless filing (electronic filing) be the preferred and most convenient
means of filing tax returns. The
Congress included provisions in the IRS Restructuring and Reform Act of 1998
(RRA 98) to address paperless tax return filing and set goals for the IRS. For example, the RRA 98 requires the IRS to
have at least 80 percent of all tax returns e-filed by the year 2007 and, to the extent practicable, ensure that all tax
returns prepared electronically after 2001 are e-filed. The Congress also established a
provision to promote and encourage the benefits and use of electronic tax
administration programs, as they become available, through mass communications
and other means. Since the passage of
the RRA 98, the IRS’ e-file marketing budget has increased from $273,000 to approximately
$22 million in 2002.
Since the enactment of the
RRA 98, the IRS has made a significant effort to make e-filing easier and continues to identify opportunities and create
incentives for taxpayers to e-file.
These efforts have resulted in taxpayers being able to electronically
sign their tax returns, e-file their state tax returns with their Federal
tax returns, pay their taxes using a credit card, e-file 99 percent of all tax forms, and e-file at no cost. Furthermore,
in an attempt to encourage paid preparers to submit tax returns electronically,
the IRS offers specific support services and is in the process of providing
incentives exclusive to e-file providers. These incentives will include the ability to apply to become an e-file provider online, interact with the IRS by email, and obtain client transcripts
online.
The IRS has made significant
progress in attracting taxpayers to e-file. Taxpayers participating in e-file
have increased from
24.6 million for TY 1997 to 46.8 million for TY 2001. However, the current rate of e-file growth is
slowing and will not enable the IRS to meet its e-file goal of 80
percent by 2007. Therefore, it is
essential that the IRS focus on taxpayers and paid preparers that have not e‑filed,
particularly those that continue to file computer-prepared paper tax
returns.
As the IRS strives to
increase e‑filing by transitioning individual taxpayers and
preparers from mailing their computer-prepared tax returns, the IRS needs to
address the following issues to help ensure its success:
·
The IRS does not currently
identify all tax returns that are computer-prepared and submitted on
paper.
·
The IRS does not
currently have a process to measure the effectiveness of all aspects of its
marketing and outreach activities.
·
The current marketing
strategy does not include individuals that use computer software packages to
self-prepare their tax returns and submit them on paper.
E-filing provides significant benefits to both taxpayers and
the IRS. Over
46.7 million taxpayers that submitted TY 2001 computer-prepared paper tax
returns did not receive the benefits associated with e-filing, including faster
refunds, more accurately processed tax returns, and quick acknowledgement that
the IRS received their tax returns. In
addition, the IRS estimates the processing of an e-filed tax return
compared to that of a paper tax return results in cost savings of approximately
$2.30 per tax return.
We recommended the Deputy
Commissioner for Services and Enforcement ensure the IRS (1) identifies all
computer-prepared paper returns submitted on paper, (2) develops a process to measure e-file outreach and marketing activities,
and (3) develops a marketing strategy to transition individual taxpayers that
self-prepare computer-prepared paper returns to e-filing.
Management’s Response: IRS
management agreed with our recommendations and has initiated corrective
actions. Specifically, the IRS will
require tax examiners to v‑code all computer-generated U.S. Individual
Income Tax Return (Form 1040) series paper tax returns, has developed an e-file
Outreach Strategy and a standard measurement system using several data sources
to evaluate the results of marketing efforts, and will include the specific
targeting of v-coded return filers in marketing efforts. Management’s complete response to the
draft report is included as Appendix V.
Copies
of this report are also being sent to the IRS managers affected by the report
recommendations. Please contact me at
(202) 622-6510 if you have questions or Michael R. Phillips, Assistant Inspector General for Audit (Wage and
Investment Income Programs), at (202) 927-0597.
Significant Effort Has Been Made
to Increase Participation in E-File
Computer-Prepared Paper Tax Returns Continue to Be the Largest Opportunity for Meeting E-File Goals
Appendix
I – Detailed Objective, Scope, and Methodology
Appendix
II – Major Contributors to This Report
Appendix
III – Report Distribution List
Appendix IV
– Outcome Measures
Appendix V –
Management’s Response to the Draft Report
The Internal Revenue Service (IRS) is the largest processor of information in the world. For Tax Year (TY) 2001, approximately 80 million (63 percent) of the 126 million individual tax returns that it processed were filed on paper. However, it is the policy of the Congress that paperless filing (electronic filing, or e-filing) be the preferred and most convenient means of filing tax returns. The Congress included provisions in the IRS Restructuring and Reform Act of 1998 (RRA 98) to address paperless tax return filing and set goals for the IRS. For example, the RRA 98 requires the IRS to have at least 80 percent of all tax returns e-filed by the year 2007 and, to the extent practicable, ensure that all tax returns prepared electronically after 2001 are e-filed.
The Congress also established a provision to promote
and encourage the benefits and use of electronic tax administration programs,
as they become available, through mass communications and other means. Since the passage of the RRA 98, the IRS’ e-file marketing budget
has increased from $273,000 to approximately $22 million in 2002.
When filing their tax returns,
individual taxpayers have the option to either e-file or submit their tax
returns on paper to the IRS. E-filed
tax returns and paper filed
tax returns can be prepared either by the taxpayer (self‑prepared)
or by someone other than the taxpayer (paid preparer).
When taxpayers submit their tax
returns on paper, the IRS classifies the tax returns into two categories:
Hand-prepared tax returns – Tax returns that are handwritten.
Computer-prepared
paper tax returns – Tax returns prepared
using a computer software tax package but submitted to the IRS on paper rather
than being e-filed.
IRS employees identify and code computer-prepared
paper tax returns with a “V.” This process is referred to as v‑coding. Although the IRS uniquely codes the
computer‑prepared paper tax returns, it processes them in the same manner
in which it processes hand‑prepared tax returns. The processing of paper tax returns requires
IRS employees to manually input tax return information into IRS computers.
Chart 1 shows the percentage of e-file tax returns, computer‑prepared
paper tax returns, and hand‑prepared
tax returns for TY 2001.
Chart 1
Chart 1 was removed due to its size. To see Chart 1, please go to the Adobe PDF version of the report on the TIGTA Public Web Page.
This review was performed at the IRS National Headquarters and the Office of Electronic Tax Administration in Washington, D.C.; the Wage and Investment (W&I) Division Headquarters in Atlanta, Georgia; and the Small Business/Self-Employed (SB/SE) Division Headquarters in New Carrollton, Maryland. We conducted our audit during the period February through November 2003.
The audit was conducted in accordance with Government Auditing Standards. Detailed information on our audit objective, scope, and methodology is presented in Appendix I. Major contributors to the report are listed in Appendix II.
The IRS recognizes the need to promote the benefits of e‑file and encourages taxpayers and paid preparers to e-file. Since the enactment of the RRA 98, the IRS has made a significant effort to make e-filing easier and continues to identify opportunities and create incentives for taxpayers to e-file. For example:
· Taxpayers can now sign their tax returns using an electronic signature. For TY 2001, 24.7 million taxpayers signed their electronically filed tax returns using a Personal Identification Number in lieu of a written signature.
· Taxpayers can e-file their Federal and state tax returns together. The IRS has formed a partnership with 37 states so taxpayers living in these states have this option. For TY 2001, 19.3 million taxpayers filed both their Federal and state tax returns with a single electronic transmission.
· Taxpayers can pay their taxes using a credit card. In TY 2002, over 768,000 payments were made electronically by credit card or electronic withdrawal from a checking or savings account.
·
Taxpayers can now file 99 percent of all tax forms
electronically.
In addition, the IRS has identified that the cost associated with e-filing is the largest barrier to an individual taxpayer’s willingness to e-file. To address the cost issue, the IRS entered into an agreement with a number of tax preparation software companies to provide no-cost e-filing to individual taxpayers that meet certain requirements. For TY 2002, 119 million of the estimated 127 million individual taxpayers met the requirements to e-file a tax return at no cost.
The IRS Advisory
Council reports that paid preparers file nearly 60 percent of all individual
tax returns. In addition, segments of
the preparer community have adopted e‑filing
as their principal way of doing business.
However, the Council reported that, while paid preparers produce 72 percent
of all computer-prepared tax returns, only 46 percent of these paid preparers e-file. If all paid preparers e-filed,
it would put the IRS past its goal of having 80 percent of all tax returns e-filed by the year 2007.
In an attempt to
encourage paid preparers to submit tax returns electronically, the IRS plans to
provide incentives exclusive to e-file providers (preparers that e-file tax
returns). For those preparers that are e-file providers, the IRS offers specific support services including:
·
Quick Alerts – a
messaging system that disseminates (within seconds, by email or telephone)
information regarding the e-file Program.
·
An e-file Toll-Free Assistance Helpdesk that addresses e‑file questions and concerns.
·
An e‑file web page on the IRS Internet.
· On-line business tools, including an online application for a preparer tax identification number and the ability to verify the accuracy of taxpayer identification numbers.
In addition, the IRS is in the process of releasing a series of “E-Services” for third parties that participate in the e‑file Program. E-Services will provide the ability to apply to become an authorized e-file provider online, electronically receive account transcripts for clients, and communicate by email with the IRS.
The IRS’ e-file improvements, promotions, and
incentives have resulted in the steady growth of the e-file Program. Chart 2 shows the increase of e-filed tax returns.
Chart 2
Chart 2 was removed due to its size. To see Chart 2, please go to the Adobe PDF version of the report on the TIGTA Public Web Page.
As shown in Chart 2, the IRS has made significant progress
in attracting taxpayers to e-file.
The General Accounting Office (GAO) recently reported that the current rate of growth of e‑filing
is slowing and will not allow the IRS to achieve its long‑term e-file
goal of 80 percent by 2007, despite a number of initiatives implemented
over the years to reduce barriers and encourage more e-filing.
Provisions included in the RRA 98 directed the IRS, to the extent practicable, to ensure that all tax returns prepared electronically after 2001 are e-filed. Therefore, it is essential that the IRS focus its efforts on those taxpayers and paid preparers that have not e-filed, particularly those that continue to file computer‑prepared paper tax returns.
The IRS recognizes taxpayers and paid preparers that file computer‑prepared paper tax returns provide an opportunity for furthering its e-file goals and plans to aggressively address this issue. Chart 3 shows that, although the number of computer-prepared paper tax returns is decreasing, 46.7 million were filed for TY 2001.
Chart 3
Chart 3 was removed due to its size.
To see Chart 3, please go to the Adobe PDF version of the report on the
TIGTA Public Web Page.
As the IRS strives to increase e-filing by transitioning individual taxpayers and paid preparers from
submitting computer-prepared paper tax returns to e-filing, the following
issues need to be addressed to help ensure success.
The IRS does not currently identify all tax returns
that are computer-prepared and submitted on paper
Currently, the IRS identifies computer‑prepared paper tax returns submitted using U.S. Individual Income Tax Return (Form 1040) and U.S. Individual Income Tax Return (Form 1040A). Guidelines require that IRS employees processing paper tax returns identify and v‑code only computer-prepared Forms 1040 and 1040A tax returns. The IRS identifies those tax returns so it can suppress future mailings of IRS tax packages. The IRS decided that, if individuals purchase IRS-approved tax preparation software packages to prepare their tax returns, sending the tax packages would not be cost-effective for the IRS or necessary for the taxpayers to prepare and file their tax returns in the future.
IRS guidelines do not include the requirement to identify and v‑code computer-prepared paper tax returns filed using Income Tax Return for Single and Joint Filers With No Dependents (Form 1040EZ). However, IRS employees are not consistently following the guidelines. For example, our review of TY 2001 data files identified approximately 217,000 Form 1040EZ tax returns that had been v‑coded, even though IRS employees are not required to v-code these tax returns.
Currently there are 66 IRS-approved electronic tax preparation software packages that taxpayers and paid preparers can use to prepare a Form 1040EZ tax return, which may then be submitted to the IRS as a computer‑prepared paper tax return. During TY 2001, a total of 10.7 million Form 1040EZ tax returns were submitted on paper to the IRS. Because the IRS does not require the Form 1040EZ to be v-coded, there is no way to identify the volume that are computer-prepared paper tax returns.
Although the IRS’ original intent of identifying and v‑coding tax returns was to reduce mailing and postage costs, the IRS is now using the information to develop and target its marketing and outreach strategies in an effort to reduce this population. Therefore, it is essential that all Form 1040 series tax returns be identified. Inconsistent identification may result in underestimating the volume of individual taxpayers that file computer-prepared tax returns and may eliminate some taxpayers from being included in the IRS’ marketing and outreach efforts.
The IRS does not currently have a process to measure
the effectiveness of all aspects of its marketing and outreach activities
The IRS is currently in the process of finalizing plans for
its Fiscal Year (FY) 2004 marketing and outreach strategy, which will focus on
paid preparers that submit computer‑prepared tax returns. For TY 2001, paid preparers filed 33.9 million
(73 percent) of the 46.7 million computer-prepared paper tax returns. Although plans are being developed, the IRS
has not developed a process to timely and consistently measure the
effectiveness of its marketing and outreach activities.
For FY 2004, the IRS plans to undertake aggressive marketing and outreach campaigns coordinated by its W&I Division Office of Stakeholder Partnerships, Education, and Communication (SPEC) and SB/SE Division Office of Taxpayer Education and Communication (TEC). These offices educate and inform taxpayers and paid preparers about their tax obligations by developing educational products and services focused on customer needs and by providing top-quality pre‑filing services to help taxpayers understand and comply with the tax laws.
The SPEC and TEC offices have developed a joint strategy that outlines the steps that will be taken to identify each organization’s targeted audience. The goal is to ensure the organizations do not duplicate efforts (each organization visiting the same preparer). The targeted audience for each organization is as follows:
· The SPEC office will focus its outreach and marketing efforts on paid preparers that file primarily individual tax returns. These preparers are usually authorized e-file providers. The goal of the SPEC office’s outreach and marketing is to increase the number of tax returns these preparers e-file. The SPEC office plans include field visits, telephone contacts, seminars, and mailings.
· The TEC office will focus its outreach and marketing efforts on paid preparers that file primarily business tax returns and are not always authorized e-file providers. The goal of TEC office’s outreach and marketing is to get these preparers to become authorized e-file providers. The TEC office plans include field visits and seminars.
Although both offices are committed to a joint strategy, they have yet to implement a process to consistently capture the results of each office’s outreach efforts. In addition, despite having outreach efforts since FY 2002, the SPEC office has yet to develop a standard measurement process to measure the effectiveness of its outreach efforts. The SPEC office has progressed in its efforts to develop a standard measurement process. It is analyzing and evaluating its previous measurement efforts to identify those steps to be included in a standard measurement process. The SPEC office met with its Research function in December 2003 to discuss how to design such a measurement process.
The TEC office has coordinated with its Research function since the inception of its outreach efforts to develop a process to measure the effectiveness of its outreach and marketing activities. However, because of delays in getting the necessary data to perform this measurement, it is still attempting to measure the effectiveness of its outreach efforts performed in FYs 2002 and 2003.
Each office will have to address its inability to timely measure
the effectiveness of its efforts resulting primarily from delays in obtaining
the necessary data needed for this measurement analysis. For example, the FY 2004 strategy calls for
the SPEC and TEC offices to conduct their outreach efforts between June and
December 2004. However, delays in
obtaining the necessary data timely will result in the inability to completely
measure the effectiveness of the outreach efforts until February 2006
(approximately 20 months after the marketing strategy is initiated).
Without a timely and consistent method to measure its e-file outreach and marketing efforts,
the IRS may not have the ability to effectively adjust its strategy or make
informed business decisions on the impact that one or more of its marketing and
outreach efforts may be having on transitioning taxpayers from
computer-prepared paper tax returns to e-file.
The current marketing strategy does not include
individuals that use computer software packages to self‑prepare their tax
returns and submit them on paper
The FY 2004 marketing and outreach strategy planned by the SPEC and TEC offices primarily targets computer-prepared paper tax returns submitted by paid preparers. However, of the 46.7 million computer-prepared paper tax returns submitted for TY 2001, a total of 12.8 million (27 percent) were self‑prepared (taxpayers used computer software packages to prepare their own tax returns and submit them on paper to the IRS). The IRS has the ability to identify these taxpayers, but the SPEC and TEC offices do not have plans to aggressively market to these taxpayers.
Without an aggressive marketing strategy by the IRS, individuals that self-prepare might not understand the numerous benefits of e-file and might continue to mail their computer-prepared paper tax returns. These taxpayers present further opportunities for the IRS to increase e-file.
After
we discussed our results with IRS management, they agreed taxpayers that
self-prepare computer-prepared paper tax returns should be included in marketing
and outreach efforts. Specifically,
management agreed to evaluate the possibility of direct mailing to these
individuals, especially to inform them of the IRS’ partnership with the
electronic tax preparation software industry that could result in e-filing
at no cost. Management indicated that
they plan to implement the
direct mail recommendation in their 2004 marketing strategy.
The effect of transitioning individual taxpayers from
computer-prepared paper tax returns to e-file
E-filing provides significant benefits to both taxpayers and the IRS. For example:
·
The approximately 46.7 million taxpayers that use
computer software packages to prepare tax returns yet submit them on paper are
not receiving the benefits associated with e-file,
including faster refunds, more
accurately processed tax returns, and quick acknowledgement that the IRS
received the tax returns.
· The IRS estimates the processing of an e-filed tax return compared to that of a paper tax return results in processing cost savings of approximately $2.30 per tax return. If the approximately 46.7 million taxpayers that submit computer-prepared paper tax returns elected to e-file these tax returns, the potential processing cost savings would have exceeded $107 million for TY 2001 and could be $537 million over 5 years. (See Appendix IV for more details.)
The Deputy Commissioner for Services and Enforcement should ensure the IRS:
1. Accurately and consistently identifies all tax returns that are computer-prepared and submitted on paper.
Management’s Response: The IRS will revise Internal Revenue Manual 3.11.3, Returns and Document Analysis, for the 2005 Filing Season to instruct tax examiners to v-code all computer-generated Form 1040 series paper tax returns. This revision will be effective in January 2005.
2.
Develops
a standard measurement process to consistently and
timely measure e-file outreach and marketing activities.
Management’s Response: For FYs 2004 and beyond, the W&I Division SPEC and SB/SE Division TEC offices have segmented the preparer database primarily along individual and business filing components. Each organization developed complementary marketing strategies that target their respective preparer segments. For FY 2004, the SPEC office developed an e-file Outreach Strategy and a standard measurement system. In addition, the SPEC and TEC offices will use several data sources to evaluate results of marketing efforts. The SPEC and TEC offices will continue to work with the W&I and SB/SE Divisions’ Research functions to determine the feasibility of combining research projects and standardizing the measurement process.
3. Develops a direct marketing strategy focusing on transitioning individual taxpayers that self-prepare computer-prepared paper tax returns to e-filing.
Management’s
Response: The IRS will include the
specific targeting of v-coded return filers through the Statement of Work and
contract with its vendor as part of the overall FY 2005 advertising
effort. The IRS will send Isn’t it
time you e-filed? (Publication 8160E) to targeted individuals. It will also survey selected recipients on
the perceived effectiveness of this Publication and monitor the actual e-file
rate of individual recipients as opposed to other individuals who did not
receive the Publication.
Appendix I
Detailed Objective, Scope,
and Methodology
The overall objective of this review was to assess the Internal Revenue Service’s (IRS) efforts to reduce the volume of tax returns prepared using computer software packages but submitted to the IRS on paper instead of being electronically filed (e-filed). To accomplish this objective, we:
I. Determined what efforts the IRS has taken to identify the volume and characteristics of taxpayers that prepare their tax returns using computer software but submit the tax returns to the IRS on paper (referred to as computer-prepared paper tax returns).
A. Determined if the IRS accurately identifies all computer-prepared paper tax returns.
B. Obtained and reviewed IRS statistics on computer-prepared paper tax returns.
C. Performed a walk-through of the Code and Edit function to determine how the IRS codes computer‑prepared paper tax returns.
D. Obtained an extract from the Treasury Inspector General for Tax Administration Data Center Warehouse to determine whether volumes of computer-prepared paper tax returns are consistently coded and identify limitations to the IRS’ ability to identify computer-prepared paper tax returns.
E. Determined if the IRS accurately or completely captured computer-prepared paper tax returns.
F. Determined the impact to both the taxpayer and the IRS.
II. Determined what IRS strategies and efforts have been taken to reduce the volume of computer-prepared paper tax returns.
A. Determined if the IRS has a documented strategic plan outlining initiatives to be taken to reduce computer-prepared paper tax returns.
B. Discussed strategies planned or completed with appropriate IRS management.
C. Determined whether the IRS used information provided by research projects to design initiatives to reduce the volume of computer-prepared paper tax returns.
D. Determined whether the IRS has undertaken sufficient efforts to reduce the volume of computer-prepared paper tax returns.
E. Computed the impact on both the taxpayer and the IRS relating to taxpayer burden and IRS cost savings.
Appendix II
Major Contributors to This Report
Michael R. Phillips, Assistant Inspector General for Audit (Wage and Investment
Income Programs)
Randee Cook, Director
Russell Martin, Audit Manager
Lena Dietles, Senior Auditor
Robert Baker, Auditor
Mary Keyes, Auditor
Joseph Butler, Information Technology Specialist
Kevin O’Gallagher, Information Technology Specialist
Jeffrey Williams, Information Technology Specialist
Appendix III
Commissioner C
Office of the
Commissioner – Attn: Chief of
Staff C
Commissioner, Small Business/Self-Employed Division SE:S
Commissioner, Wage and Investment Division SE:W
Acting Deputy Commissioner, Small Business/Self-Employed Division SE:S
Deputy Commissioner, Wage and Investment Division SE:W
Chief Communications and Liaison CL
Deputy Chief, Information Technology Services OS:CIO:I
Director, Communications, Wage and Investment Division SE:W:C
Director, Customer Assistance, Relationships, and Education, Wage and Investment Division SE:W:CAR
Director, Strategy and Finance, Wage and Investment Division SE:W:S
Director, Taxpayer Education and Communication, Small Business/Self-Employed Division SE:S:T
Director, Communications and Liaison, Small Business/Self-Employed Division SE:S:MS:CL
Director, Electronic Tax Administration, Information Technology Services OS:CIO:I:ET
Director, Stakeholder Partnerships, Education, and Communication, Wage and Investment Division SE:W:CAR:SPEC
Director, Submission Processing, Wage and Investment Division SE:W:CAS:SP
Chief Counsel CC
National Taxpayer Advocate TA
Director, Office of Legislative Affairs CL:LA
Director, Office of
Program Evaluation and Risk Analysis
RAS:O
Office of
Management Controls OS:CFO:AR:M
Audit Liaison:
Chief, Customer Liaison, Small Business/Self-Employed Division SE:S:COM
GAO/TIGTA Liaison, Wage and Investment Division SE:W:S:PA
Appendix IV
This appendix presents detailed information on the measurable impact that our recommended corrective actions will have on tax administration. These benefits will be incorporated into our Semiannual Report to the Congress.
Type and Value of Outcome Measure:
Methodology Used to Measure the Reported Benefit:
The Internal Revenue Service (IRS) provided us the volume of v-coded tax returns for TYs 1997 through 2000. Through the Treasury Inspector General for Tax Administration Data Center Warehouse, we retrieved the volume of tax returns filed for TY 2001.
Type and Value of Outcome Measure:
Methodology Used to Measure the Reported Benefit:
The IRS provided the cost of $2.86 to process a paper tax return and $.56 to process an e-filed tax return. We calculated the difference in cost ($2.86 - $.56 = $2.30). We multiplied the 46.7 million tax returns by the difference in cost to get the total cost savings (46.7 million multiplied by $2.30 = $107.4 million multiplied by 5 years).
Appendix V
Management’s Response to
the Draft Report
The response was removed due to its size. To see the response, please go to the Adobe
PDF version of the report on the TIGTA Public Web Page.