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entitled 'Applying Agreed-Upon Procedures: Federal Unemployment Taxes' 
which was released on November 05, 2005.

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November 5, 2004:

The Honorable Gordon S. Heddell:
Inspector General:
Department of Labor:

Subject: Applying Agreed-Upon Procedures: Federal Unemployment Taxes:

Dear Mr. Heddell:

We have performed the procedures contained in the enclosure to this 
report, which we agreed to perform and with which you concurred, solely 
to assist your office in ascertaining whether the net federal 
unemployment tax (FUTA) revenue distributed to the Unemployment Trust 
Fund (UTF) for the fiscal year ended September 30, 2004, is supported 
by the underlying records. As agreed with your office, we evaluated 
fiscal year 2004 activity affecting distributions to the UTF.

In performing the agreed-upon procedures, we conducted our work in 
accordance with U.S. generally accepted government auditing standards, 
which incorporate financial audit and attestation standards established 
by the American Institute of Certified Public Accountants. These 
standards also provide guidance for performing and reporting the 
results of agreed-upon procedures.

The adequacy of the procedures to meet your objectives is your 
responsibility, and we make no representation in that respect. The 
procedures we agreed to perform include (1) detailed tests of 
transactions that represent the underlying basis of amounts distributed 
to the UTF and (2) review of key reconciliations of the Internal 
Revenue Service records to the Department of the Treasury records. The 
enclosure contains the agreed-upon procedures and our findings from 
performing each of the procedures.

We were not engaged to perform, and did not perform, an audit, the 
objective of which would have been the expression of an opinion on the 
net amount of FUTA taxes distributed to the UTF. Accordingly, we do not 
express such an opinion. Had we performed additional procedures, other 
matters might have come to our attention that would have been reported 
to you. We completed the agreed-upon procedures on October 27, 2004.

We provided a draft of this report to IRS officials for review and 
comment. They agreed with the results and findings presented in this 
report.

This report is intended solely for the use of the Office of Inspector 
General of the Department of Labor and should not be used by those who 
have not agreed to the procedures and have not taken responsibility for 
the sufficiency of the procedures for their purposes. However, this 
report is a matter of public record, and its distribution is not 
limited. Copies are available to others upon request. This report is 
also available at no charge on GAO's Web site at http://www.gao.gov. If 
you have any questions, please call me at (202) 512-3406.

Sincerely yours,

Signed by: 

Steven J. Sebastian:

Director:

Financial Management and Assurance:

Enclosure:

Unemployment Trust Fund Procedures and Results:

I. Detailed tests of transactions:

A. Obtain from the Internal Revenue Service (IRS) total Federal 
Unemployment Tax (FUTA) collections and refunds reflecting the first 8 
months of fiscal year 2004 posted to the master file.[Footnote 1] 
Determine whether FUTA collections and refund data per the master file 
materially reconcile to the general ledger.[Footnote 2]

Description of findings and results:

Total FUTA collections and refunds for the first 8 months of fiscal 
year 2004 per IRS's master file materially reconciled to IRS's general 
ledger.

B. Use dollar unit sampling (DUS) to select a sample of combined FUTA 
collection and refund transactions from the master file for the first 8 
months of fiscal year 2004, using a confidence level of 80 percent, a 
test materiality of $374 million, and an expected aggregate error 
amount of $112 million.

Description of findings and results:

Use of DUS with a confidence level of 80 percent, a test materiality 
of $374 million, and an expected aggregate error amount of $112 million 
resulted in a sample of 40 transactions for the first 8 months of 
fiscal year 2004. All of the 40 transactions represented collection 
sample items.

C. For each sampled FUTA tax collection transaction:

1. Determine whether collection amounts are accurately recorded by 
tracing collection transaction amounts from IRS's master files to 
supporting documents (e.g., federal tax deposit coupons).

Description of findings and results:

Based on supporting documentation, collection amounts were accurately 
recorded for all 40 sampled FUTA collection transactions.

2. Determine whether amounts were recorded to the appropriate period by 
reviewing the date on source documents.

Description of findings and results:

Based on supporting documentation, collection amounts were recorded to 
the appropriate period for all 40 sampled FUTA collection transactions.

3. Determine whether the transactions were properly classified as FUTA 
receipts by reviewing source documentation maintained in IRS's files 
(e.g., tax returns).

Description of findings and results:

Based on supporting documentation, collection amounts were recorded in 
the correct tax class[Footnote 3] for 39 of the 40 sampled 
transactions. One sampled transaction, which was classified as a FUTA 
receipt, should have been classified as a corporate tax payment (tax 
class 3). IRS discovered the error and made the correction after our 
sample cutoff date but before the end of the fiscal year.

Based on our testing results, the net most likely error for the first 8 
months of fiscal year 2004 is $141 million. The net upper error limit 
is $414 million.

4. Confirm FUTA transactions paid via the Electronic Federal Tax 
Payment System (EFTPS)[Footnote 4] to determine whether the recorded 
transactions are valid and reflect the proper amounts, are applied to 
the proper tax period, and are properly classified as FUTA receipts.

Description of findings and results:

Of the 40 sampled FUTA collection transactions, 33 were paid via EFTPS. 
The bank confirmations showed that all 33 transactions were valid and 
had been recorded to the proper tax period and tax class and for the 
proper amounts.

II. Analytical procedures:

A. Perform analytical procedures on FUTA revenue collection and refund 
data for the period not subject to detailed tests of transactions to 
determine whether reported fiscal year 2004 revenue collections and 
refunds appear reasonable.

Description of findings and results:

We performed a predictive test on the final 4 months of fiscal year 
2004 FUTA revenue collection and refund data. The predicted FUTA 
revenue collection and refund data amounts for the final 4 months of 
fiscal year 2004 did not materially vary from the actual amount of 
revenue collections and refunds per IRS's records for this period.

III. Other FUTA procedures:

A.For each of the 12 months in fiscal year 2004, obtain and review 
supporting documentation for monthly revenue reclassification 
adjustments transmitted by IRS to the Department of the Treasury's 
Financial Management Service (FMS). Check to see whether the supporting 
documentation agrees with the reclassification adjustment transmitted 
to FMS.

Description of findings and results:

Documentation supported the monthly FUTA reclassification adjustment 
amount transmitted to FMS for all 12 months of fiscal year 2004.

B. For each of the 12 months in fiscal year 2004, obtain and review 
supporting documentation for the monthly entry of FUTA refund data into 
the Government Online Accounting Link System (GOALS) to charge back the 
Unemployment Trust Fund (UTF) account for FUTA tax refunds issued. 
Check to see whether the supporting documentation agrees with the 
monthly entries reported on GOALS.

Description of findings and results:

Documentation supported the monthly FUTA refund amount entered into 
GOALS to charge the UTF for FUTA tax refunds issued for all 12 months 
of fiscal year 2004.

C. Compare fiscal year 2004 net FUTA collections per IRS's draft 
statement of custodial activity and related footnote disclosures to (a) 
the Treasury's Bureau of the Public Debt (BPD) accounting records for 
the UTF and (b) drafts of the Department of Labor's (DOL) consolidated 
financial statements.

Description of findings and results:

There were no significant variances between net FUTA collections per 
IRS's draft statement of custodial activity and BPD's accounting 
records for UTF. Similarly, there were no significant variances between 
IRS's draft statement of custodial activity and related footnote 
disclosures and drafts of DOL's fiscal year 2004 consolidated financial 
statements.

IV.Other procedures performed as part of the fiscal year 2004 IRS 
financial statement audit:

A. From IRS's master files for the first 8 months of fiscal year 2004, 
use DUS to select statistical samples of (1) total tax revenue receipts 
and (2) refunds. For each sample item, test whether the collection or 
refund amount, tax period, and tax class from source documentation 
agree with those recorded in IRS's master files.

Description of findings and results:

Detailed testing of 135 revenue receipts and 48 refund sample 
transactions showed that the collection or refund amount, tax period, 
and tax class from source documentation agreed with those recorded in 
IRS's master files.

B. Review selected IRS service center campuses' monthly Treasury SF-224 
reconciliations to determine whether IRS-reported revenue receipts were 
properly classified and reconciled to Treasury FMS records. For 
refunds, review selected IRS service center campuses' monthly Treasury 
SF-224 reconciliations to determine whether IRS-reported total refunds 
(all tax classes) materially[Footnote 5] reconciled to Treasury FMS 
records.[Footnote 6]

Description of findings and results:

Tax revenue receipts reported by selected IRS service center campuses 
through the monthly Treasury SF-224 reconciliation process were 
properly classified and materially reconciled to Treasury FMS records.

Total refunds reported by selected IRS service center campuses through 
the monthly Treasury SF-224 reconciliation process materially 
reconciled to Treasury FMS records.

C. Perform procedures to determine whether tax revenue receipt balances 
by tax class, including FUTA, recorded in IRS's general ledger 
materially agree with IRS's master files and Treasury records. For 
refunds, perform a comparison of total refund balances between the 
master files, the general ledger, and Treasury records.

Description of findings and results:

Tax receipt balances for all tax classes, including FUTA, per IRS's 
general ledger, materially agreed with IRS's master files and Treasury 
records.

Refund balances per IRS's general ledger materially agreed with the 
master files and with Treasury records.

(196008):

FOOTNOTES

[1] The master file is a detailed database containing taxpayer 
information.

[2] Except where noted for certain procedures, "significant" or 
"material" is defined as $374 million. This represents 1 percent of net 
Unemployment Trust Fund collections for fiscal year 2003.

[3] IRS assigns a tax class number to specific types of taxes. FUTA 
taxes are tax class 8.

[4] EFTPS is a Financial Management Service system maintained by two 
financial agents for the government. EFTPS is used for initiating tax 
payments electronically. Employers who make federal tax deposits 
exceeding $200,000 must use EFTPS to pay their FUTA taxes. The $200,000 
threshold includes all federal tax deposits, such as deposits for 
employment tax, excise tax, and corporate income tax. Taxpayers who are 
not required to make electronic deposits may voluntarily participate in 
EFTPS.

[5] For the purpose of this procedure and procedure IV.C, we define 
"material" as $20 billion. This represents 1 percent of the estimated 
total tax revenue receipts collected by IRS in fiscal year 2004.

[6] IRS maintains records of refund balances by tax class in its master 
file and reports this information monthly to Treasury on the SF-224. 
Treasury provides IRS with a Statement of Differences (TFS-6652), which 
reports differences between total refunds reported by IRS on the SF-224 
and the total refunds in Treasury records.