The Internal Revenue Service Needs to Improve
Information Systems Quality Assurance
Efforts over Key Tax Law Changes
for the 2000 Filing Season
September 1999
Reference Number: 199920066
September 29, 1999
MEMORANDUM FOR COMMISSIONER ROSSOTTI
FROM: Pamela J. Gardiner /s/Pamela J. Gardiner
Deputy Inspector General for Audit
SUBJECT: Final Audit Report – The Internal Revenue Service Needs to Improve Information Systems Quality Assurance Efforts over Key Tax Law Changes for the 2000 Filing Season
This report presents the results of our review of Information Systems’ quality assurance efforts over key tax law changes for the 1999 Filing Season. We evaluated the effectiveness of the Internal Revenue Service’s (IRS) process for monitoring the programming changes necessary to implement the key legislative changes affecting the 1999 Filing Season. In addition, we focused on evaluating the quality and timeliness with which the required programming changes were completed and tested.
In summary, we found that the IRS needs to develop and improve processes to ensure that the status of programming changes for the 2000 Filing Season is adequately monitored and accurately reported.
To ensure that the IRS can effectively monitor and accurately report the status of programming changes for the 2000 Filing Season, we recommended that Information Systems management ensure that the Filing Season Project Office have controls in place to monitor and oversee the progress of filing season changes. We also recommended that Product Assurance management ensure that the progress of testing is monitored consistently and that any delays are timely reported to the Executive Steering Committee (ESC) and during weekly filing season progress meetings.
Management generally concurred with the findings and recommendations in the report and has taken appropriate corrective actions. However, management stated that none of the program testing delays cited in the report led to production delays. In addition, management did not agree that all delays should be elevated to the ESC. We believe that the ESC should be timely informed of late legislative changes to programs that may affect testing schedules or possible program implementation delays for the 2000 Filing Season. This is important for the upcoming filing season because of shortened time frames for implementing program changes, competing demands for programming resources for the Service Center Mainframe Consolidation, and Year 2000 century date change conversion.
All of management’s comments have been incorporated into the report where appropriate, and the full texts of their comments are included as appendices.
Copies of this report are also being provided to the IRS managers who are affected by the report recommendations. Please contact me at (202) 622-6510 if you have any questions, or your staff may call Scott E. Wilson, Associate Inspector General for Audit (Information Systems Programs), at (202) 622-8510.
Issues Reported During the Review and Responded to by Internal Revenue Service Management
Appendix I - Detailed Objective, Scope, and Methodology
Appendix II - Major Contributors to This Report
Appendix III - Report Distribution List
Appendix V - Management’s Response to Memorandum #1
Appendix VI – 1999 Filing Season Requests for Information Services for Key Tax Law Changes
Appendix VII – Management’s Response to the Draft Report
The Taxpayer Relief Act of 1997 (TRA 97) contained over 800 Internal Revenue Code amendments and nearly 300 new provisions, most of which went into effect prior to the 1999 Filing Season. As a result, the Internal Revenue Service (IRS) was required to prepare its systems and programs to properly process tax return information mandated by this new legislation for the 1999 Filing Season. The IRS had other initiatives for which programming resources were needed as well. These initiatives included consolidating computer operations of 10 service centers into 2 computer centers and preparing all IRS systems for Year 2000 compliance.
The overall objective of this audit was to evaluate the effectiveness of the IRS’ process for monitoring the programming changes necessary to implement the key legislative changes affecting the 1999 Filing Season. In addition, we focused on evaluating the quality and timeliness with which the required programming changes were completed and tested.
Results
We determined that the IRS incorporated key legislative changes into programs, ensured unit testing2 was completed, and promptly forwarded programs to the Product Assurance Division for System Acceptability Testing (SAT).3 However, the IRS needs to improve processes to ensure that the status of programming changes for the 2000 Filing Season is adequately monitored and accurately reported for a successful filing season.
The IRS Needs to Ensure the Status of Programming Changes for the 2000 Filing Season Is Adequately and Effectively Monitored
The IRS was not adequately or effectively monitoring the status of programming changes, Requests for Information Services (RIS), for the 1999 Filing Season. The Filing Season Project Office, established to monitor and track the status of projects for the 1999 and 2000 Filing Seasons, was not tasked with analyzing or verifying the information it consolidated from the various Information Systems areas, including the status of SAT. IRS executives cannot effectively make decisions regarding the status of filing season changes without accurate status information. The need for accurate information is even greater for the 2000 Filing Season because the time period for making and releasing programming changes for production is shortened. If the progress of RIS implementation is not adequately and effectively monitored, the IRS may not timely identify programming delays. An unanticipated demand for limited programming resources could result and necessary 2000 Filing Season programming changes may not be completed.
The Product Assurance Division Needs to Ensure the Status of System Acceptability Testing Is More Completely, Accurately, and Timely Reported
The Product Assurance Division4 does not have a process to ensure that SAT progress is fully and accurately reported. In addition, Product Assurance is not always completely, timely, or consistently reporting the status of SAT for all projects nor problems affecting SAT critical milestone dates. The IRS may not have the time and resources available to ensure that programs are adequately tested before they are placed into production or prevent program implementation delays if SAT progress and problems are not accurately reported before the 2000 Filing Season.
Summary of Recommendations
To ensure that the IRS can effectively monitor and accurately report the status of programming changes for the 2000 Filing Season, we recommend that Information Systems management ensure that the Filing Season Project Office have controls in place to monitor and oversee the progress of all filing season changes. We also recommend that Product Assurance Division management ensure that the progress of testing for the 2000 Filing Season is consistently monitored and reported. Furthermore, we recommend that any testing delays are timely reported and discussed at the IRS Commissioner’s Executive Steering Committee (ESC) and weekly filing season progress meetings.
Management’s Response: For the 2000 Filing Season, Information Systems management evaluated and updated the Filing Season Project Office’s procedures related to information gathering and reporting to more effectively monitor and document milestone date changes and the resulting impact on the Product Assurance Division’s testing and filing season implementation. Product Assurance management also reviewed the Division’s procedures and determined that each Branch in the Division will create a matrix to consistently track the relevant milestone dates, within the respective Branch, for the filing season. Project milestones which affect test schedules will be reported through the Product Assurance Division’s various reporting mechanisms, such as weekly filing season meetings held at the Assistant Commissioner and Director level. For the 2000 Filing Season, Product Assurance management began monitoring compliance to the Division’s various reporting mechanisms through the filing season weekly status meetings, performance reviews with Division management, and review of the Division’s Weekly Exception Report. Product Assurance management, however, stated that none of the program testing delays cited in the report led to production delays. In addition, management did not believe it would be appropriate to raise all program problems to the ESC. Management’s complete response to the draft report is included as Appendix VII.
Office of Audit Comment: We do not believe monitoring the compliance to Product Assurance Division’s various reporting mechanisms alone will ensure that the ESC is timely informed of late legislative changes to programs that may affect SAT schedules or possible program implementation delays for the 2000 Filing Season. As reported, we found that program delays were not consistently or timely reported using these mechanisms during the 1999 Filing Season. Therefore, we believe that all program changes or problems that may have an impact on milestone completion dates need to be discussed with the customer and the ESC.
Issues Reported During the Review and Responded to by IRS Management
In a memorandum dated October 19, 1998, we recommended that Information Systems management assign responsibility for establishing a process to reduce the time to complete RIS responses and ensure responses are issued as quickly as possible to avoid delays. Excessive delays in completing responses increase the risk that program changes and testing will not be completed in the required time periods, causing a negative effect on the overall success of the 2000 Filing Season. The memorandum is included as Appendix IV to this report. The Filing Season Project Office agreed and implemented several processes to facilitate faster responses for Filing Season 2000 RISs. These processes included: meeting with the Assistant Commissioner (Program Management and Engineering), to ensure that RISs are forwarded to the application divisions within one to two days; incorporating milestone dates for the submission of fully coordinated RISs into Senior Executive Service expectations, for both the customer and Information Systems executives; establishing milestones for the Pre-Coordination and Clearance of RISs; and creating the Filing Season 2000 Baseline Change Procedures to provide guidelines and procedures for processing RISs for the 2000 Filing Season. Management’s response to the memorandum is included as Appendix V.
We initiated this audit as part of the efforts, undertaken by the Treasury Inspector General for Tax Administration’s (TIGTA) Office of Audit, to advise Internal Revenue Service (IRS) management whether the IRS is ready to timely and effectively adapt the key provisions from legislation enacted for 1998 and reduce the risks associated with implementing the key provisions affecting the 1999 Filing Season. The overall objective of this review was to evaluate the IRS’ process for monitoring, completing, and testing programming changes necessary to effectively implement the key legislative provisions of the Taxpayer Relief Act of 1997 (TRA 97) affecting the 1999 Filing Season. We focused our review on 19 key provisions of the TRA 97, as presented in Appendix VI.
We conducted this audit at the IRS National Office and the Ogden Service Center from August 1998 to February 1999. Audit work was performed in accordance with Government Auditing Standards. Appendix I contains the detailed objective, scope, and methodology for our review. A listing of major contributors to this report is shown in Appendix II.
This audit report presents both audit results not previously reported and a summary of the memorandum issued during the review. A copy of the memorandum is included in this report as Appendix IV, and management’s response to the memorandum is presented as Appendix V.
The TRA 97 contained over 800 Internal Revenue Code amendments and nearly 300 new provisions, most of which went into effect prior to the 1999 Filing Season. To properly process tax return information affected by the new legislation, the IRS needed to develop and implement programming changes to its tax processing systems. These programming changes were initiated with Requests for Information Services (RIS). The IRS established the Filing Season Project Office to monitor and track the status of RISs for the 1999 and 2000 Filing Seasons and ensure RISs are timely implemented into the processing systems.
The following is a simple overview on the workflow of programming changes. Information Systems program developers take RISs and translate them into the necessary programming language. They then complete unit testing on their programs to ensure the programs and subroutines are free of logic, syntax, and design errors. They may also complete compatibility testing to ensure programs accurately process data received from external sources and accurately pass the data forward to subsequent programs and/or systems. Program developers then forward the programming changes to the Product Assurance Division. The Product Assurance Division is responsible for planning, developing, scheduling, and conducting System Acceptability Testing (SAT) for programming changes. The purpose of SAT is to independently assess the quality of applications software, using controlled data, to aid the customer in determining a system’s production readiness. Any concerns about a system’s readiness should be addressed during SAT. The Product Assurance Division is required to write a SAT plan which includes an overview of the testing that will be done, the resources needed to complete the testing, and time periods for its completion.
It also conducts weekly meetings with division directors, customers, the Filing Season Project Office, and other Information Systems personnel to discuss the status of SAT. It produces Weekly Exception Reports to address problems that may delay or stop the SAT for a particular project. In addition, the branch chiefs in the Product Assurance Division produce reports to track and discuss the status of projects undergoing SAT in their particular areas.
The IRS properly incorporated key legislative changes of the TRA 97 into programs in preparation for the 1999 Filing Season. In addition, program developers performed adequate unit1 and/or compatibility2 testing for the key changes. Unit testing was completed in accordance with the Unit Test Process Procedures Handbook and included quality reviews of programming changes. Further, once changes were completed and unit tested, programs were promptly forwarded to the Product Assurance Division for SAT.
In its effort to monitor the status of programming changes for the 1999 Filing Season and provide the best available information to IRS management, the Filing Season Project Office consistently evaluated and updated its procedures and processes.
Although the IRS did incorporate the key legislative changes for the 1999 Filing Season into programs, the IRS did not have an adequate process to effectively monitor the overall status of the 1999 Filing Season changes. Therefore, the IRS needs to improve its current process to ensure that future filing season program changes are adequately and effectively monitored, as well as completed and tested timely. In addition, the Product Assurance Division needs to ensure that the status and progress of SAT is more completely, accurately, and timely reported to the IRS Commissioner’s Executive Steering Committee (ESC) and oversight management. If these conditions continue to exist during the preparation for the 2000 Filing Season, the completion, testing, and implementation of program changes could be delayed. Furthermore, tight time and resource constraints exist during calendar year 1999 for the completion and testing of all Information Systems program changes, including the Year 2000 century date change conversions and end-to-end testing.3 As a result, there is an increased risk that programming changes for the Filing Season 2000 will not be completed timely. This may negatively affect the overall success of the 2000 Filing Season.
The Internal Revenue Service Needs to Ensure the Status of Programming Changes for the 2000 Filing Season Is Adequately and Effectively Monitored
Personnel in the Filing Season Project Office began monitoring efforts over RISs and related programming changes for the 1999 Filing Season in April 1998. They tracked the status of programming changes through the RIS’ development, issuance, and response. They then relied on the applications development areas and the Product Assurance Division to provide them with weekly project information on the status of RIS completion and any delays in testing. The Project Office summarized this information in its weekly Schedule and Status Reports. However, the Project Office’s monitoring and oversight efforts did not ensure that the changes were completed and tested prior to implementation.
To report on the overall status of filing season changes, the Project Office consolidated the information obtained from the various Information Systems areas. However, it was not responsible for analyzing or verifying the accuracy of this information. Therefore, the Project Office was unable to accurately report overall progress delays or assess whether delays would affect the overall success of the filing season. For example, information contained in the weekly Schedule and Status Reports from one reporting period had later been changed or updated in subsequent reporting periods. In comparing the Schedule and Status Report for August 19, 1998, with the report for October 21, 1998, we identified that the Refund Input Request project, which was originally outside the 1999 Filing Season window for changes, was added to the schedule for SAT. In addition, the SAT status had changed from "yes," meaning a project would be subject to SAT by the Product Assurance Division, to "no," meaning a project would not be subject to SAT by the Product Assurance Division, for four other projects.4
Our review of these revisions made to the Schedule and Status Reports led to uncertainty regarding the accuracy of the information being reported and whether the updates would lead to delays in implementing 1999 Filing Season changes. While the Project Office provided valid reasons for the changes, the reasons were not analyzed at the time, nor were they explained or documented in the Schedule and Status Reports. The Project Office did not begin commenting on these changes until November 1998.
Due to the critical time periods that must be met for the 2000 Filing Season, the IRS needs to have accurate information on the status of program changes. Due to the large number of RISs scheduled for implementation each filing season, the IRS needs to present an accurate picture of the status and progress of these RISs. The need for accurate information is even greater for the 2000 Filing Season because all program changes are scheduled to be released from the Product Assurance Division in October 1999, rather than January 2000. The shortened time period for implementing program changes, and issues surrounding the Year 2000 century date change conversion, could negatively affect the completion of the RISs and, ultimately, the success of the 2000 Filing Season.
Recommendation
1.
Information Systems management should ensure the Filing Season Project Office is tasked with establishing management controls to monitor and oversee the overall progress of changes for the 2000 Filing Season.Management’s Response: Information Systems management has evaluated and updated the Filing Season Project Office’s procedures related to information gathering and the reporting of RIS statuses. For example, Filing Season Project Office management now requires any changes to the milestone dates for the Documentation to SAT or Programs Transmitted to SAT columns on the Schedule and Status Report to follow an authentication procedure, described as follows. Division level sign-off from the responsible application programming area documenting the date change and the resulting impact on the Product Assurance Division’s testing and filing season implementation is now required, as is the Product Assurance Division’s concurrence.
Information Systems management also stated that the Filing Season Project Office is now much more involved in ensuring the accuracy of RIS data submitted by the various Information Systems areas.
The Product Assurance Division Needs to Ensure the Status of System Acceptability Testing Is More Completely, Accurately, and Timely Reported
The Product Assurance Division does not ensure that the status of all projects/systems is reported completely and timely. As a result, the Product Assurance Division does not accurately report problems that could affect project milestone completion dates, which can lead to delays that may affect production dates. Below are examples noted during our review:
Accuracy and Timeliness Examples:
- Through January 1999, the ESC was not informed of delays in the SAT completion dates for the State Retrieval Subsystem, Electronic Management System (EMS), the Electronic Federal Tax Payment System, and U. S. Income Tax Return for Estates and Trusts (Electronic Filing System 1041). The Electronic Submission Testing Branch Chief’s reports had documented possible delays with EMS every month since October 1998.
- A programming problem related to the Child Tax Credit, a key provision for the 1999 Filing Season, was discovered on November 6, 1998, when the output review could not be completed. The problem, which could not be corrected until an amended request for additional programming changes was prepared, was not reported in the Product Assurance Division’s Weekly Exception Reports until December 19, 1998.
- Late legislative changes resulted in the need for additional 1999 Filing Season changes for Electronic Filing (ELF). These changes need to undergo SAT before being implemented, which could have limited Product Assurance Division’s resources available to work on the January-February 1999 end-to-end test for the Year 2000 conversion. The need for additional ELF testing for the 1999 Filing Season was not documented in the Product Assurance Division’s Weekly Exception Reports or the Electronic Submission Testing Branch Chief’s reports.
Completeness Examples:
- For the Graphical Electronic Filing List Programs:
- Through January 16, 1999, the Graphical Electronic Filing List Project was not listed on the weekly SAT Project List. Further, the project status was not tracked or captured in the Electronic Submission Testing Branch Chief’s weekly reports until December 5, 1998. The SAT Plan, which was approved on July 22, 1998, documented that SAT was scheduled to begin in September 1998.
- The SAT Plan documents that testing was scheduled to be completed by December 18, 1998. However, the weekly Electronic Submission Testing Branch Chief’s reports, dated December 5, 1998 through December 19, 1998, document that testing was on schedule for a January 29, 1999, completion date. There was no mention of SAT being delayed or re-scheduled in the Electronic Submission Testing Branch Chief’s weekly status reports or in the minutes from the ESC meetings held through January 1999.
- The Product Assurance Division does not consistently track a project with SAT problems, or exceptions, from inception through resolution. For example, the problem with the Child Tax Credit was first reported in the Product Assurance Division’s Weekly Exception Report for December 19, 1998. However, the exception was not documented or monitored in subsequent reports.
- The Product Assurance Division does not consistently report on the SAT milestone completion dates for projects from week to week. For example, the weekly Submission Processing Branch Chief’s status reports do not document the percentage milestones are completed, while the weekly Electronic Submission Testing Branch Chief’s status reports track the percentages that documentation, data preparation, and program processing are complete. The Product Assurance Division’s weekly SAT Project List tracks only SAT completion dates for projects.
It is critical that there are no unanticipated testing delays for the 2000 Filing Season. Due to programming demands for end-to-end testing, the Service Center Mainframe Consolidation5, and issues surrounding the Year 2000 century date change conversion, the SAT for 2000 Filing Season changes is scheduled to be completed three months earlier, in October 1999, rather than January 2000. Therefore, it is critical that there are no unanticipated SAT delays for the 2000 Filing Season. An accurate and timely reflection of SAT status is necessary for IRS management to effectively: (1) avoid testing delays; (2) allow others to react to problems or delays identified; (3) obtain additional resources that may be needed; (4) address staff shortages; or (5) meet the critical time periods for the 2000 Filing Season.
Recommendations
- Completion of data preparation.
- Input, processing, and output reviews of testing.
- System interface processing.
Management’s Response: Product Assurance Division’s management thoroughly reviewed the procedures followed within the organization when monitoring test milestones against an individual test team’s progress. Product Assurance Division determined that each Branch will create a matrix to be used to track relevant milestones within their Branch. Section Chiefs will be responsible for tracking project milestones and reporting project status. Project milestones which affect test schedules will be reported through Product Assurance’s various mechanisms, such as the weekly meetings held at the Assistant Commissioner and Director level between the Division and Systems Development.
Management’s Response: Product Assurance Division’s management has already taken steps to ensure that program problems are reported promptly in their Weekly Status Report, which is distributed to the Chief Information Officer (CIO) and the Deputy CIOs. In addition, program problems, once reported, are being followed through to conclusion in the reporting process. Furthermore, for the 2000 Filing Season, the Deputy Assistant Commissioner for Product Assurance will monitor compliance with the Division’s various reporting mechanisms through the weekly filing season status meetings, performance reviews with Product Assurance Division’s management, and review of the Weekly Status Report. Product Assurance Division’s management stated that none of the program testing delays cited in the report led to production delays. In addition, management did not believe it was appropriate to raise every program problem to the ESC.
Office of Audit Comment: We do not believe that monitoring the compliance to Product Assurance’s reporting mechanisms alone will ensure that the ESC is timely informed of late legislative changes needing testing or possible program implementation delays for the 2000 Filing Season. In addition, we found that program delays were not consistently or timely reported using these mechanisms during the 1999 Filing Season. Therefore, we believe that all program changes or problems that may have an impact on milestone completion dates need to be discussed with the customer and the ESC. Most of Product Assurance’s SAT plans already document that the SAT team’s ability to complete testing on schedule may be impacted by the passage and signing of legislation causing major modifications to system documentation and the need for additional review and testing of computer programs.
Issues Reported During the Review and Responded to by Internal Revenue Service Management
We reported that, although 1999 Filing Season RIS responses were technically completed timely, according to the response due date procedures documented in the Requirements Management Document, responses6 for 17 of the 19 RISs actually took more than 30 calendar days to complete. These responses were not received in a reasonable time period7, considering the IRS’ competing priorities for Information Systems resources and the criticality to the success of the 1999 Filing Season. Since the time period for completing programming changes will be shortened for the 2000 Filing Season, Information Systems must identify ways to reduce the actual calendar days required to complete RIS responses. We recommended that Information Systems assign responsibility for monitoring the status of responses to RISs for the 2000 Filing Season to ensure they are being completed within 30 calendar days.
Management’s Response: The Filing Season Project Office agreed that, due to the shortened development cycle for the 2000 Filing Season, all RISs will need to be responded to more quickly than normal. The Filing Season Project Office documented that they had already implemented several processes to facilitate faster responses for Filing Season 2000 RISs. These processes included: 1) meeting with the Assistant Commissioner (Program Management and Engineering), to ensure RISs were forwarded to the application divisions within two days to avoid delays in formulating the RIS response; 2) incorporating milestone dates for the submission of fully coordinated RISs into Senior Executive Service expectations for both customer and Information Systems executives; 3) establishing milestones for the Pre-coordination and Clearance of RISs to track the progress of RISs prior to submission; and 4) creating a "Filing Season 2000 Baseline Change Procedures" document, which provides guidelines and procedures for processing RISs for Filing Season 2000 and was the basis for building the Filing Season 2000 Baseline.
Due to the shortened time frame for implementing program changes, programming demands for end-to-end testing, the Service Center Mainframe Consolidation, and issues surrounding the Year 2000 century date change conversion, it is critical that there are no unanticipated delays, which might impact the success of the 2000 Filing Season. We determined that the IRS needs to improve processes to ensure that the status of programming changes for the 2000 Filing Season is adequately monitored and accurately reported for a successful filing season. An accurate and timely reflection of the status of programming changes is necessary for IRS management to effectively: (1) avoid testing delays; (2) allow others to react to problems or delays identified; (3) obtain additional resources that may be needed; (4) address staff shortages; and (5) meet the critical time periods for the 2000 Filing Season.
Appendix I
Detailed Objective, Scope, and MethodologyThe objective of our review was to evaluate the Internal Revenue Service’s (IRS) process to monitor the Requests for Information Services (RIS), make the required programming changes, and test the programming changes necessary to effectively implement the key legislative provisions affecting the 1999 Filing Season. Specifically, we:
Appendix II
Major Contributors to This ReportScott Wilson, Associate Inspector General for Audit (Information Systems Programs)
Michael Phillips, Director
Edward Coleman, Audit Manager
Kent Sagara, Audit Manager
Barbara Bartuska, Senior Auditor
Yolanda Betancourt, Auditor
Bobbie Draudt, Auditor
Richard Louden, Auditor
Melinda Pope, Auditor
Appendix III
Report Distribution ListDeputy Commissioner Operations C:DO
Chief Information Officer IS
Deputy Chief Information Officer, Systems IS
Assistant Commissioner for Systems Development IS:S
Assistant Commissioner for Product Assurance IS:PA
Deputy Chief Information Officer for Information Resources Management IS:IR
Director, Submission Processing Division IS:S:SP
Director, Corporate Processing Division IS:S:CP
Project Director, Filing Season IS:S:FS
Chief Operations Officer OP
Deputy Chief Operations Officer OP
Assistant Commissioner (Forms & Submission Processing) OP:FS
Assistant Commissioner (Program Evaluation and Risk Analysis) M:OP
National Director for Legislative Affairs CL:LA
Office of Management Controls M:CFO:A:M
Audit Liaison, Office of Program Oversight IS:PM:O
Appendix IV
Memorandum #1Memorandum #1 has been removed due to its size. To see the complete Memorandum, please go to the Adobe PDF version of this report.
Appendix V
Management’s Response to Memorandum #1
Response has been removed due to its size. To see the complete Response, please go to the Adobe PDF version of this report
Appendix VI
1999 Filing Season Requests for Information Services for Key Tax Law Changes
1. ETA-8-0014: Acceptance of Automated Clearing House Debit Payment Transactions in Electronic Filing for Full Pay Balance Due Returns Except Telefile
Appendix VII
Management’s Response to the Draft Report
Response has been removed due to its size. To see the complete Response, please go to the Adobe PDF version of this report.