Tax Administration
Expanded Information Reporting Could Help IRS Address Compliance Challenges with Forgiven Mortgage Debt Gao ID: GAO-10-997 August 31, 2010To assist the growing number of taxpayers facing foreclosure or mortgage restructuring, the Mortgage Forgiveness Debt Relief Act of 2007, and its 3-year extension as part of the Emergency Economic Stabilization Act of 2008, allows taxpayers to generally exclude from taxable income forgiven mortgage debt used to buy, build, or substantially improve a principal residence. Joint Committee on Taxation (JCT) estimates originally suggested that the exclusion of forgiven mortgage debt from taxable income may result in about $968 million in federal revenue losses from fiscal year (FY) 2008 through FY 2013 and more recent estimates suggest that the revenue losses could be closer to $1.9 billion. The Department of Treasury estimates suggest that the exclusion may result in federal revenue losses of about $1.4 billion from FY 2008 through FY 2013. Some taxpayers with forgiven mortgage debts may be bankrupt or insolvent; however, others are not and therefore may have the ability to pay taxes on forgiven mortgage debts. The briefing slides summarize our assessment of the Internal Revenue Service's (IRS) administration of this tax provision. In response to your request, our objectives were to identify 1. the number of taxpayers who have reported the exclusion of forgiven mortgage debt since the program's inception and the dollar amount excluded; 2. the challenges, if any, IRS faces in administering the exclusion and evaluate how effectively IRS is addressing the challenges; and 3. the challenges, if any, taxpayers could face in understanding whether forgiven mortgage debt can be excluded from taxable income and evaluate how to address these challenges.
IRS estimates suggest the dollar amount of forgiven mortgage debt excluded from income could be significant. IRS Statistics of Income (SOI) officials estimate that for tax year 2008, the most current tax year for which data are available, about 126,000 to 169,000 returns included a Form 982, excluding a total of about $15.2 billion to $24.6 billion of forgiven debt from taxable income. IRS estimates suggest that for about 61,000 to 93,000 of the returns with a Form 982, forgiven debt for a qualified principal residence was the only type of forgiven debt, and taxpayers excluded about $6.4 billion to $11.8 billion from taxable income. Additionally, because taxpayers excluding multiple types of debt from income are only required to report the total amount being excluded and not the amount for each individual type, IRS lacks data to determine the dollar amount of forgiven mortgage debt excluded for these taxpayers. IRS faces several compliance challenges in administering this complicated tax provision. IRS officials reported that it may be difficult to collect additional taxes on forgiven debts, particularly when taxpayers are already insolvent and defaulting on debts, and that this and other considerations, such as IRS's return on investment, would affect IRS's decisions about allocating resources for enforcing this provision. However, there is evidence some taxpayers have the ability to pay additional tax if owed, and certain housing market data show that the potential for significant noncompliance with the exclusion of forgiven mortgage debt exists. Over the last 5 years, vacation home and investment property purchases are estimated to have ranged from 40 percent (2005) to 27 percent (2009) of home sales. Current IRS forms provide limited information on mortgage debt forgiveness and IRS is not making full use of all available data. For example, 1) Form 982 does not contain enough information to allow IRS to check for compliance because the form cannot be easily matched against information received from lenders on Form 1099-C. Form 982, Part 1 uses check boxes instead of dollars to report the amount of forgiven debt being excluded. As a result, IRS cannot determine what dollar amounts are being excluded for each type of qualified cancelled debt. 2) Form 1099-C instructions ask lenders to provide an open-ended description of the type of cancelled debt, but do not require the lender to uniformly identify the specific type of cancelled debt. For example, the form does not use a series of check boxes or apply codes so that lenders could select among a list of common cancelled debt types (e.g., mortgage, home equity line of credit, credit card, auto loan, etc.). 3) Neither Form 982 nor Form 1099-C requires the taxpayer or lender to disclose the address of the property secured by the forgiven debt. According to IRS officials, collecting such information might not result in a perfect match in all cases across the two forms. However, it would allow IRS to better determine whether the forgiven debt is for a principal residence. Further, we previously recommended, that IRS consider collecting the address of the secured property on Form 1098, "Mortgage Interest Statement," for taxpayers deducting mortgage interest to help determine the home's use and eligibility for the deduction and improve compliance for taxpayers reporting rental real estate activity. IRS agreed to study the issue. 4) Without being able to systematically identify whether the forgiven debt is for a mortgage, IRS also cannot identify taxpayers who may be eligible for the provision, but are not taking advantage of it. 5) IRS is not using available internal or third-party data to determine whether taxpayers with forgiven mortgage debt own multiple homes--also a potential indicator that the forgiven debt is not for a principal residence.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: James R. White Team: Government Accountability Office: Strategic Issues Phone: (202) 512-5594GAO-10-997, Tax Administration: Expanded Information Reporting Could Help IRS Address Compliance Challenges with Forgiven Mortgage Debt
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Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
August 2010:
Tax Administration:
Expanded Information Reporting Could Help IRS Address Compliance
Challenges with Forgiven Mortgage Debt:
GAO-10-997:
Contents:
Letter:
Background:
Results:
Conclusions:
Recommendations for Executive Action:
Agency Comments:
Appendix I: Updated Slides from the July 28, 2010 Congressional
Briefing:
Appendix II: Comments from the Department of the Treasury:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
August 31, 2010:
The Honorable Max Baucus:
Chairman:
The Honorable Charles E. Grassley:
Ranking Member:
Committee on Finance:
United States Senate:
The Honorable John Lewis:
Chairman:
The Honorable Charles W. Boustany, Jr.
Ranking Member:
Subcommittee on Oversight:
Committee on Ways and Means:
House of Representatives:
To assist the growing number of taxpayers facing foreclosure or
mortgage restructuring, the Mortgage Forgiveness Debt Relief Act of
2007, and its 3-year extension as part of the Emergency Economic
Stabilization Act of 2008, allows taxpayers to generally exclude from
taxable income forgiven mortgage debt used to buy, build, or
substantially improve a principal residence.[Footnote 1]
Joint Committee on Taxation (JCT) estimates originally suggested that
the exclusion of forgiven mortgage debt from taxable income may result
in about $968 million in federal revenue losses from fiscal year (FY)
2008 through FY 2013 and more recent estimates suggest that the
revenue losses could be closer to $1.9 billion.[Footnote 2] The
Department of Treasury estimates suggest that the exclusion may result
in federal revenue losses of about $1.4 billion from FY 2008 through
FY 2013.[Footnote 3] Some taxpayers with forgiven mortgage debts may
be bankrupt or insolvent; however, others are not and therefore may
have the ability to pay taxes on forgiven mortgage debts.
The briefing contained in appendix I, provided to your offices on July
28, 2010, and subsequently updated, summarizes our assessment of the
Internal Revenue Service's (IRS) administration of this tax provision.
In response to your request, our objectives were to identify:
1. the number of taxpayers who have reported the exclusion of forgiven
mortgage debt since the program's inception and the dollar amount
excluded;
2. the challenges, if any, IRS faces in administering the exclusion
and evaluate how effectively IRS is addressing the challenges; and:
3. the challenges, if any, taxpayers could face in understanding
whether forgiven mortgage debt can be excluded from taxable income and
evaluate how to address these challenges.
To meet these objectives, we worked with IRS officials to determine
the availability of information on the tax treatment of forgiven
mortgage debt; analyzed IRS data on the number and dollar amounts of
canceled debts between 2007 and June 2010; analyzed related forms and
publications, education and outreach materials, and actions taken by
IRS to inform taxpayers, tax software companies, and paid preparers
about the tax treatment of canceled mortgage debt; reviewed a selected
sample of tax preparation software packages from tax software
providers that cover 90 percent of the market; and interviewed IRS
officials and housing market experts familiar with the current
condition of the housing market, including trends in foreclosure and
debt cancellation. We interviewed IRS officials about how they
produced estimates on the number and dollar amount of forgiven debts
and the reliability of those estimates. We also interviewed housing
market experts that we frequently consult about data such as
foreclosures and home sales, and determined that the data included in
this briefing were sufficiently reliable for our purposes.
We conducted this performance audit from July through August 2010 in
accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our
findings and conclusions based on our audit objectives.
Background:
Taxpayers are to report all canceled debt, including mortgage debt,
excludable from taxable income by completing Form 982, "Reduction of
Tax Attributes Due to Discharge of Indebtedness (and Section 1082
Basis Adjustment)." Taxpayers use Part 1 of this form to report
reasons why canceled debt can be excluded from taxable income.
Taxpayers who are in bankruptcy or insolvent are to exclude their
forgiven mortgage debt under the bankruptcy or insolvency category on
the Form 982. Taxpayers with forgiven mortgage debt who are not
bankrupt or insolvent are to exclude forgiven mortgage debt under the
qualified principal residence category on the Form 982. Thus, these
taxpayers may have the ability to pay taxes on forgiven debts because
they are not in bankruptcy or insolvent. Lenders report all types of
canceled debts to IRS on Form 1099-C, "Cancellation of Debt.":
With some exceptions, a canceled or modified debt is considered
taxable income for taxpayers who are not insolvent or in bankruptcy.
Without the Mortgage Forgiveness Debt Relief Act and its extension,
millions of homeowners currently facing foreclosure could be liable
for income taxes on the discharge of debt on their principal residence.
Results:
IRS estimates suggest the dollar amount of forgiven mortgage debt
excluded from income could be significant. IRS Statistics of Income
(SOI) officials estimate that for tax year 2008, the most current tax
year for which data are available, about 126,000 to 169,000 returns
included a Form 982, excluding a total of about $15.2 billion to $24.6
billion of forgiven debt from taxable income. IRS estimates suggest
that for about 61,000 to 93,000 of the returns with a Form 982,
forgiven debt for a qualified principal residence was the only type of
forgiven debt, and taxpayers excluded about $6.4 billion to $11.8
billion from taxable income. Additionally, because taxpayers excluding
multiple types of debt from income are only required to report the
total amount being excluded and not the amount for each individual
type, IRS lacks data to determine the dollar amount of forgiven
mortgage debt excluded for these taxpayers.
IRS faces several compliance challenges in administering this
complicated tax provision. IRS officials reported that it may be
difficult to collect additional taxes on forgiven debts, particularly
when taxpayers are already insolvent and defaulting on debts, and that
this and other considerations, such as IRS's return on investment,
would affect IRS's decisions about allocating resources for enforcing
this provision. However, as noted above, there is evidence some
taxpayers have the ability to pay additional tax if owed, and certain
housing market data show that the potential for significant
noncompliance with the exclusion of forgiven mortgage debt exists. For
example, housing market experts who publish regular foreclosure and
delinquency surveys confirmed to us that mortgages on vacation and
investment homes may account for a substantial portion of current
delinquencies and foreclosures. Over the last 5 years, vacation home
and investment property purchases are estimated to have ranged from 40
percent (2005) to 27 percent (2009) of home sales.[Footnote 4] Current
IRS forms provide limited information on mortgage debt forgiveness and
IRS is not making full use of all available data. For example,
* Form 982 does not contain enough information to allow IRS to check
for compliance because the form cannot be easily matched against
information received from lenders on Form 1099-C. Form 982, Part 1
uses check boxes instead of dollars to report the amount of forgiven
debt being excluded. As a result, IRS cannot determine what dollar
amounts are being excluded for each type of qualified canceled debt.
* Form 1099-C instructions ask lenders to provide an open-ended
description of the type of canceled debt, but do not require the
lender to uniformly identify the specific type of canceled debt. For
example, the form does not use a series of check boxes or apply codes
so that lenders could select among a list of common canceled debt
types (e.g., mortgage, home equity line of credit, credit card, auto
loan, etc.).
* Neither Form 982 nor Form 1099-C requires the taxpayer or lender to
disclose the address of the property secured by the forgiven debt.
According to IRS officials, collecting such information might not
result in a perfect match in all cases across the two forms. However,
it would allow IRS to better determine whether the forgiven debt is
for a principal residence. Further, we previously recommended, that
IRS consider collecting the address of the secured property on Form
1098, "Mortgage Interest Statement," for taxpayers deducting mortgage
interest to help determine the home's use and eligibility for the
deduction and improve compliance for taxpayers reporting rental real
estate activity. IRS agreed to study the issue.[Footnote 5]
* Without being able to systematically identify whether the forgiven
debt is for a mortgage, IRS also cannot identify taxpayers who may be
eligible for the provision, but are not taking advantage of it.
* IRS is not using available internal or third-party data to determine
whether taxpayers with forgiven mortgage debt own multiple homes--also
a potential indicator that the forgiven debt is not for a principal
residence.
Without having an estimate of the extent of noncompliance, IRS is
unable to determine whether additional resources should be dedicated
to compliance monitoring for mortgage debt forgiveness or if automated
compliance checks are needed.
At the same time, little concrete information exists to measure the
extent to which paid preparers and taxpayers experience difficulty
adhering to mortgage debt forgiveness provisions due to the complexity
of the law, IRS forms, and instructions. However, anecdotal evidence
suggests IRS's forms and instructions and the related tax laws are
difficult to understand. For example, IRS officials acknowledged that
the law is confusing and the National Taxpayer Advocate described Form
982 as "technically challenging."[Footnote 6] As a result, IRS has
taken actions to reduce the complexity associated with filing the Form
982, including revising the form's instructions and engaging in
outreach to paid preparers and software providers on canceled debt.
Currently, the most frequently used commercial software packages
provide varying degrees of support for Form 982. In addition, IRS has
not explored several low-cost and easy-to-implement options that could
help it clarify how to treat forgiven mortgage debt for tax purposes.
These options include the following:
* Releasing to paid preparers, software companies, or taxpayers an
existing interactive tool on cancellation of debt which is similar to
tools already released for other tax laws in that it enables users to
navigate a series of questions about taxpayers' particular canceled
debt circumstances. IRS officials reported that making this tool
publicly available would introduce some additional costs. However,
based on our observation of the tool, it may clarify the tax treatment
of forgiven debt, including mortgage debt, for tax purposes.
* Using telephone software to analyze the reasons why taxpayers call
IRS with questions about the tax treatment of forgiven mortgage debt.
* Encouraging software companies to provide more interactive features
that would help taxpayers answer a series of questions about more
complex canceled debt situations, and, if applicable, subtract
ineligible amounts of debt from the total being excluded from income.
Conclusions:
IRS is responsible for enforcing complex tax laws and must consider
trade-offs when allocating its enforcement resources, such as the
ability to collect assessed taxes and return on investment.
Deteriorating trends in the housing market have led to an increase in
the number and amount of forgiven mortgage debts, which have complex
tax consequences. However, IRS is missing opportunities to both
identify noncompliance and assist eligible taxpayers in excluding
forgiven mortgage debt before the provision expires at the end of
2012. Revising the forms, collecting more information from taxpayers
and lenders, and using third-party data would help IRS determine
whether taxpayers are correctly excluding mortgage debt from taxable
income and whether IRS needs to dedicate additional resources to this
issue. Further, providing greater assistance to taxpayers and
expanding outreach to stakeholders are low-cost solutions that could
help better highlight the potential tax consequences of canceled debts.
Recommendations for Executive Action:
We recommend that the Commissioner of Internal Revenue take the
following nine actions.
1. To enhance IRS's ability to detect noncompliance with mortgage debt
forgiveness provisions,
2. modify Form 982, Part 1 to segregate the total dollar amount of
forgiven debt by exclusion type and capture the information in IRS's
databases;
3. modify Form 1099-C to require lenders to identify in a more useable
format (check boxes or coding, for example) the specific type of
canceled debt and capture the information in IRS's databases;
4. modify the Form 982 and Form 1099-C so that filers disclose the
address of the secured property for which the debt is being forgiven
and capture the information in IRS's databases;
5. determine if available data (including IRS and third-party data)
would allow IRS to better identify whether the debt being excluded is
for a principal residence; and use the additional data reported on the
revised Form 982 and Form 1099-C to assess the extent to which
taxpayers are compliant.
To provide better information for paid preparers and taxpayers to
determine eligibility for excluding forgiven mortgage debt from
taxable income, explore and implement readily available low-cost
options to help clarify the tax treatment of forgiven debt, including
options such as:
6. make IRS's interactive tool for canceled debt publicly available
for the 2011 filing season;
7. use IRS's telephone software to obtain better information about
why, if at all, taxpayers call IRS with questions about forgiven
mortgage debt;
8. work with software companies to more fully support complex debt
cancellation issues, particularly those related to forgiven mortgage
debts; and:
9. either send notices to taxpayers when a lender files a Form 1099-C
indicating a forgiven mortgage and the taxpayer does not file a Form
982 or document that the costs of doing so would exceed the benefits.
Agency Comments:
We provided a draft of this report to the Commissioner of Internal
Revenue. We received written comments from the Deputy Commissioner,
Services and Enforcement; his comments are reprinted in appendix II.
He stated that IRS agreed with five of the nine recommendations and
said that the other four, related to making changes to the Forms 982
and 1099-C and collecting the resulting data, have significant value.
However, the Deputy Commissioner raised the question of whether the
costs of making the changes would outweigh the benefits and said that
before taking action on the four recommendations, IRS would ascertain
the costs and benefits.
We agree that costs and benefits should be considered, but we are not
sure a useful estimate is possible in this case. As our report states
and IRS acknowledges, the lack of data presents challenges in
estimating the extent of noncompliance and, therefore, the benefits of
additional IRS action. The Deputy Commissioner stated that IRS will
review a sample of tax returns filed with Form 982 and analyze
available third-party data to determine the character of the canceled
debt. However, our report--based on interviews with IRS officials--
said that the available third-party data reported on Form 1099-C do
not contain information in a format that could help to systematically
determine eligibility. Thus, IRS's review of a sample of tax returns
using only currently available data risks understating the benefits of
additional information reporting. To avoid the challenge of developing
a complete benefit estimate, we recommended that IRS make relatively
minor changes to the Forms 982 and 1099-C that would not impose
significant additional burden on taxpayers or third parties. By
collecting such additional data, albeit at some cost, IRS would be
better positioned to determine whether additional resources are needed
to monitor compliance with forgiven mortgage debt rules.
IRS also provided technical changes to the report, which we
incorporated where appropriate.
As agreed with your offices, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 30 days
from the report date. At that time, we will send copies to the
Chairmen and Ranking Members of other Senate and House committees and
subcommittees that have appropriation, authorization, and oversight
responsibilities for IRS. We will also send copies to the Commissioner
of Internal Revenue, the Secretary of the Treasury, the Chairman of
the IRS Oversight Board, and the Director of the Office of Management
and Budget. The report also will be available at no charge on the GAO
Web site at [hyperlink, http://www.gao.gov].
If you or your staff have any questions or wish to discuss the
material in this report further, please contact me at (202) 512-9110
or at whitej@gao.gov. Contact points for our Offices of Congressional
Relations and Public Affairs may be found on the last page of this
report. Major contributors to this report were Joanna Stamatiades,
Assistant Director; Amy Bowser; James Cook; John Dell'Osso; Tom
Gilbert; Mark Kehoe; Kirsten Lauber; Patricia MacWilliams; Jessica
Thomsen; Benjamin Wories; and Jeff Wojcik.
Signed by:
James R. White:
Director, Tax Issues Strategic Issues:
[End of section]
Appendix I: Updated Slides from the July 28, 2010 Congressional
Briefing:
Tax Administration: Expanded Information Reporting Could Help IRS
Address Compliance Challenges with Forgiven Mortgage Debt:
Senate Committee on Finance:
House Committee on Ways and Means, Subcommittee on Oversight:
Mortgage Debt Forgiveness Objectives:
1. How many taxpayers have reported the exclusion of forgiven mortgage
debt from taxable income since the program's inception and what is the
total dollar amount excluded?
2. What challenges, if any, does IRS face in administering the
exclusion of forgiven mortgage debt from taxable income and how
effectively is IRS addressing the challenges?
3. What challenges, if any, could taxpayers face in understanding
whether forgiven mortgage debt can be excluded from taxable income and
what steps can be taken to address these challenges?
Results:
IRS estimates suggest the dollar amount of forgiven mortgage debt
excluded from income could be significant.
Although conditions in the current housing market suggest that the
potential for significant noncompliance exists, IRS is unable to
measure the extent to which taxpayers are compliant with the mortgage
debt forgiveness exclusion. Information provided on IRS Forms 982 and
1099-C does not allow IRS to systematically check for noncompliance,
nor does IRS require lenders or taxpayers to report the address of the
property secured by the mortgage debt being forgiven. Without such
information, IRS is unable to determine what additional resources, if
any, are needed to ensure compliance.
The complexity of tax provisions regarding forgiven mortgage debt, as
well as IRS forms and instructions, makes it difficult for taxpayers
to determine whether and what portion of forgiven mortgage debt can be
excluded from income. However, IRS has not explored several low-cost
options that would be relatively easy to implement and would help
clarify the tax treatment of forgiven debt for tax purposes including
making existing interactive tools available, using existing telephone
software, and conducting further outreach to external stakeholders.
Scope and Methodology:
To accomplish our objectives, we:
* worked with IRS officials to determine the availability of
information related to the tax treatment of forgiven mortgage debt;
* analyzed IRS data concerning the number and dollar amount of
canceled debts from 2007 through June 2010;
* analyzed related forms and publications, education and outreach
materials, and actions taken by IRS to inform taxpayers, tax software
companies, and paid preparers about the tax treatment of canceled
mortgage debt;
* reviewed how tax software packages from companies that cover 90
percent of the market treat forgiven mortgage debt; and;
* interviewed IRS officials about a variety of issues, and housing
market experts from an industry association and a private research
company familiar with the current condition of the housing market,
including trends in foreclosure and debt cancellation.
We conducted this performance audit from July 2010 through August 2010
in accordance with generally accepted government auditing standards.
We interviewed IRS officials and housing market experts about
available data and determined that the data included in this briefing
were sufficiently reliable our purposes.
Background:
The Mortgage Forgiveness Debt Relief Act of 2007 (P.L. 110-142)
generally allows homeowners to exclude forgiven mortgage debt from
taxable income for a principal residence (subject to a variety of
restrictions that introduce varying degrees of complexity) from 2007
to 2009. The Emergency Economic Stabilization Act of 2008 (P.L. 110-
343) extended this through 2012.
* Includes both debt forgiven through foreclosure and loan
modification as long as discharge of debt was due to a decline in the
value of the residence or the financial condition of the taxpayer.
* The mortgage debt must have been used to buy, build, or
substantially improve a principal residence and must be secured by the
property.
Historically, if a lender canceled a debt, it has been subject to
taxes, with exceptions made for taxpayers who are insolvent or in
bankruptcy.
Taxpayers report mortgage debt excluded from taxable income by
completing Form 982, "Reduction of Tax Attributes Due to Discharge of
Indebtedness (and Section 1082 Basis Adjustment)." Part 1 of this form
is used to report reasons why canceled debt can be excluded from
taxable income, including:
* bankruptcy,
* insolvency,
* qualified farm indebtedness,
* qualified real property business indebtedness,
* qualified Midwestern disaster area indebtedness, or,
* qualified principal residence indebtedness.
Lenders report all types of canceled debts to IRS on Form 1099-C,
"Cancellation of Debt."
Joint Committee on Taxation (JCT) estimates originally suggested that
the exclusion of forgiven mortgage debt from taxable income may result
in about $968 million in federal revenue losses from fiscal year (FY)
2008 through FY 2013 and more recent estimates suggest that the
revenue losses could be closer to $1.9 billion.[Footnote 7] The
Department of Treasury estimates suggest that the exclusion may result
in federal revenue losses of about $1.4 billion from FY 2008 through
FY 2013.[Footnote 8]
This suggests that not all taxpayers with forgiven mortgage debt are
bankrupt or insolvent and may have the ability to pay taxes on
forgiven debts.
* Taxpayers who are in bankruptcy or insolvent are to exclude forgiven
mortgage debt under the bankruptcy or insolvency category on Form 982.
* Taxpayers with forgiven mortgage debt who are not bankrupt or
insolvent are to exclude forgiven mortgage debt under the qualified
principal residence category on Form 982.
Objective 1: IRS Estimates Suggest the Dollar Amount of Forgiven
Mortgage Debt Excluded from Income Could be Significant:
Based on a sample of 2008 tax returns, IRS Statistics of Income (SOO
officials estimate that for tax year (TY) 2008, about 126,000 to
169,000 returns included a Form 982, excluding a total of about $15.2
billion to $24.6 billion of forgiven debt from taxable income.
* IRS estimates also suggest that for about 61,000 to 93,000 of the
returns with a Form 982, debt for qualified principal residence was
the only type of forgiven debt, and taxpayers excluded about $6.4
billion to $11.8 billion from taxable income.
Because taxpayers excluding multiple types of debt only report the
total amount being excluded, and not individual debt amounts, IRS
lacks the data to determine the dollar amount of forgiven mortgage
debt excluded for these taxpayers.
Objective 2: IRS Challenges - Potential for Significant Noncompliance
Exists:
In the absence of detailed audits, IRS does not know the extent of
noncompliance for forgiven mortgage debt. However, we identified
several conditions suggesting the potential for significant
noncompliance exists.
1. Housing market data show significant amounts of forgiven mortgage
debt could be taxable income.
* Real estate market experts estimate that, in 2010, over 3 million
foreclosure filings will take place, while about 1 million homes will
be repossessed by lenders.[Footnote 9] Housing market experts who
publish regular foreclosure and delinquency surveys confirmed to us
that mortgages on vacation and investment homes may account for a
substantial portion of current delinquencies and foreclosures. Over
the last 5 years, vacation home and investment property purchases are
estimated to have ranged from 40 percent (2005) to 27 percent (2009)
of home sales.[Footnote 10]
- Taxpayers who own second homes or investment properties may differ
in their ability to pay taxes than taxpayers with a single residence.
* During the height of the housing market, homeowners withdrew
increasing amounts of housing-secured equity through refinancing,
second mortgages, and lines of credit. Estimates of the amount
withdrawn in 2005 range from $301 billion to 515 billion.[Footnote 11]
However, IRS is unable to determine whether the proceeds from these
loans were used to buy, build, or substantially improve a principal
residence.
2. IRS data show a significant increase in the amount and number of
canceled debts since TY 2007.
* IRS estimates the amount of canceled debt reported on Form 1099-C
has increased over 10 times”from about $19 billion worth of debt in TY
2007 to about $216 billion worth of debt for TY 2009 (as reported to
IRS through June 2010).
* The number of Form 1099-Cs has increased about 80 percent from about
2 million debts to about 3.6 million debts.
* However, IRS is unable to identify the extent to which this increase
is attributable to foreclosures and mortgage modifications, and
particularly to debt attributable to a principal residence.
3. IRS dedicates minimal resources in this area and is unable to
report how many returns have been subject to further examination due to
cancellation of debt issues, including forgiven mortgage debt.
* The Automated Underreporter (AUR) program does not pursue
underreported income from canceled debts over certain thresholds based
on the assumption that such canceled debts would be for mortgages and
yield little change in the amount of tax owed.
* Using a rationale similar to AUR, the Wage and Investment
examination division does not include canceled debts or mortgage debt
forgiveness as part of the examination process.
* The Small Business/Self-Employed division may include mortgage
cancellations as part of broader audits of taxpayers, including
requiring taxpayers to supply supporting documentation related to debT
cancellation.
According to IRS officials, it may be difficult to collect additional
taxes on forgiven debts, particularly when taxpayers are already
insolvent and defaulting on debts, and that this and other
considerations, such as return on investment, would affect IRS's
decisions about allocating resources for enforcing this provision.
There is evidence that some taxpayers have the ability to pay
additional tax, if owed.
* JCT and Treasury revenue loss estimates suggest that without the
exclusion, forgiven mortgage debts would generate federal revenue.
* Taxpayers selecting the qualified principal residence category on
the Form 982 are indicating that they are not in bankruptcy or
insolvent because if they were, they would be claiming the exclusion
under the "bankruptcy" or "insolvency" category on the Form 982 (as we
noted earlier).
IRS Challenges - Current IRS Forms Provide Limited Information on
Mortgage Debt Forgiveness:
Several limitations with Form 982 and Form 1099-C make it difficult
for IRS to measure noncompliance.
* Form 982 does not contain enough information to allow IRS to check
for compliance because the form cannot be matched against information
received from lenders on Form 1099-C.
- Form 982, Part 1 uses check boxes instead of dollars to report the
amount of forgiven debt being excluded. As a result, IRS cannot
determine what dollar amounts are being excluded for each type of
qualified canceled debts.
Possible changes to Form 982 to enhance compliance:
[Figure: refer to PDF for image: Form 982]
Check boxes could be replaced with actual dollar amount of the
canceled debt that the taxpayer is excluding from income.
[End of figure]
Form 1099-C does not provide information in a format that could help
determine eligibility, including what type of debt (mortgage, credit
card, car loan, etc.) is being forgiven.
* Although IRS receives nearly all 1099-C information returns
electronically, the information cannot be used by itself to determine
whether the canceled debt is for a mortgage. IRS instructions ask
lenders to be as specific as possible when describing the type of debt
being forgiven, but do not require lenders to uniformly identify the
specific type of canceled debt. For example, lenders filing 1099-Cs do
not select from a list of types of forgiven debt when completing box
4, which describes the type of debt being forgiven. Because box 4 is
an open-ended description, IRS is unable to code or quantify canceled
debts by type.
* Without being able to systematically identify whether the forgiven
debt is for a mortgage, IRS also cannot identify taxpayers who may be
eligible for the provision, but are not taking advantage of it.
Possible changes to Form 1099-C to enhance information reporting:
[Figure: refer to PDF for image: Form 1099-C]
Possible modifications:
* Box 4 could include a type of debt indicator (e.g., check boxes or
codes that would disclose the type of debt).
* If the debt is a mortgage, lenders could report which type (e.g.,
acquisition, refinance, home equity, etc.).
[End of figure]
Neither Form 982 nor Form 1099-C requires the taxpayer or lender to
disclose the address of the property secured by the forgiven debt.
According to IRS officials, collecting such information might not
result in a perfect match across the two forms in all cases. However,
it would allow IRS to better determine whether the forgiven debt is
for a principal residence.
* For example, IRS would be able to check whether the forgiven
mortgage debt is for the same address reported on current and prior
year Form 1040s, "U.S. Individual Tax Return" (which is likely to be
the taxpayer's principal residence).
^ We previously recommended that IRS collect the address of the
secured property for taxpayers deducting mortgage interest, which
could help determine the home's use and eligibility for the deduction,
and could improve compliance for taxpayers reporting rental real
estate activity.[Footnote 12]
IRS is not using available data (internal or third party) to determine
whether taxpayers with forgiven mortgage debt own multiple homes”also
a potential indicator that the forgiven debt is not on a principal
residence.
These limitations prevent IRS from determining whether the forgiven
debt can be excluded from taxable income.
However, if IRS were to modify and capture information from Form 982
and Form 1099-C, it could better measure noncompliance.
* Without having an estimate of the extent of noncompliance, IRS is
unable to determine whether additional resources should be dedicated
to compliance monitoring for mortgage debt forgiveness or if automated
compliance checks are needed.
AUR officials generally agreed that modifications to Form 982 and Form
1099-C would place little burden on IRS and taxpayers and allow IRS to
better verify the type of debt and amount that can be excluded.
Objective 3: Taxpayer Challenges - Complexities Exist in Reporting
Forgiven Mortgage Debt:
Little concrete information exists to measure the extent to which paid
preparers and taxpayers experience difficulty adhering to mortgage
debt forgiveness provisions due to the complexity of the law, IRS
forms, and instructions.
However, anecdotal evidence suggests IRS's forms and instructions and
the related tax laws are difficult to understand. For example:
* IRS officials acknowledged that the mortgage debt forgiveness law is
complex.
* The National Taxpayer Advocate described Form 982 as "technically
challenging."
* The Center for Responsible Lending (a nonprofit organization that
seeks to eliminate abusive financial practices) characterized Form 982
as "a very complicated and difficult form."
Examples illustrating the complexity of Form 982 and its instructions
include:
* multiple types of canceled debts are reported on Form 982 by both
individuals and businesses;
* title of Form 982 is difficult to understand ” "Reduction of Tax
Attributes Due to Discharge of Indebtedness (and Section 1082 Basis
Adjustment)";
* Form 982 consists of 23 lines with four pages of instructions and
includes technical terms such as "basis reduction" and "debt
discharged"; and;
* Form 982 instructions attempt to explain a difficult-to-understand
"ordering rule" that requires taxpayers to distinguish between
qualified and nonqualified debt.
IRS has taken actions to reduce the complexity associated with filing
Form 982, including:
* Revising Form 982 instructions and Publication 4681, Canceled Debts,
Foreclosures, Repossessions, and Abandonments, to explain the
requirements for excluding forgiven mortgage debt.
* Engaging in outreach to paid preparers and software providers on
canceled debt, including providing presentations and conducting focus
groups at tax forums, and issuing press releases and other
publications to clarify the tax treatment of forgiven mortgage debt.
- IRS officials said that paid preparers and software providers have
asked few questions about how forgiven mortgage debt should be treated
for tax purposes.
IRS has not explored several options that would be relatively easy to
implement and with some additional cost could help clarify how to
treat forgiven mortgage debt for tax purposes. For example,
* Beginning in March 2010, IRS pilot-tested several interactive tax
assistant tools on its Web site (e.g., Child Tax Credit, and Making
Work Pay Tax Credit). These tools are similar to commercial tax
preparation products. IRS officials reported that the test was
successful with a high completion rate for available issues. Further,
they expect to expand the number of interactive tools on IRS's Web
site for more complex tax law issues in the 2011 filing season and
beyond.
* Although IRS developed an interactive tool for canceled debt that is
used by IRS telephone and walk-in employees, IRS did not make the tool
publicly available in 2010 because it was not part of the pilot test.
* IRS officials reported that making this tool publicly available
would introduce some additional costs. However, based on our
observation of the tool, it may clarify the tax treatment of forgiven
debt, including mortgage debt, for tax purposes. Further, because the
tool provides information on all types of forgiven debts excluded from
income, it would be of value beyond 2012, when the exclusion for
mortgage debt expires.
Another low-cost option that IRS has yet to explore would involve:
* using contact analytics software (which allows IRS to analyze
recorded phone calls) to examine the reasons taxpayers call IRS with
questions about forgiven mortgage debt. IRS is in the initial stages
of using contact analytics for other purposes, and could leverage
contact analytics to help understand why taxpayers are calling about
mortgage or canceled debt.
About 90 percent of returns are prepared by individual taxpayers or
paid preparers using professional or commercial software.
* IRS National Account Managers, through regularly scheduled
conference calls, discuss issues of mutual interest with tax software
companies, including tax law changes, updates to IRS forms and
publications, and the upcoming tax filing season.
* IRS also works with software companies on an ad hoc basis to
influence and improve specific guidance provided by tax software
regarding complicated tax provisions (e.g., Earned Income Tax Credit
eligibility).
Currently, the most frequently used commercial software packages
provide varying degrees of support for Form 982; although the major
software packages generally support taxpayers with relatively simple
forgiven mortgage debt situations, they provide more limited support
for more complex situations, including instances where taxpayers have
multiple forgiven debts.
* Generally, these commercial software packages provide detailed
interactive questionnaires or worksheets to calculate other
complicated deductions (e.g., what portion of a homeowner's expenses
can be deducted for using a home office).
Conclusions:
IRS is responsible for enforcing complex tax laws and must consider
tradeoffs when allocating its enforcement resources, such as the
ability to collect assessed taxes and return on investment.
Deteriorating trends in the housing market have led to an increase in
the number and amount of forgiven mortgage debts, which have complex
tax consequences. However, IRS is missing opportunities to both
identify noncompliance and assist eligible taxpayers in excluding
forgiven mortgage debt before the provision expires in 2012.
* Revising the forms and using third-party information could provide
IRS with more information to determine whether taxpayers are correctly
excluding forgiven mortgage debt from income and whether IRS needs to
dedicate additional resources to this issue.
* Providing greater assistance to eligible taxpayers could help ensure
that homeowners understand the potential tax consequences of canceled
debts, in particular foreclosures or mortgage modifications.
* Expanding outreach efforts to external stakeholders, including
software providers, could be part of an effort to reduce common types
of misreporting related to cancellation of debt (including forgiven
mortgages).
Recommendations for Executive Action:
We recommend that the Commissioner of Internal Revenue take the
following nine actions.
To enhance IRS's ability to detect noncompliance with mortgage debt
forgiveness provisions,
1. modify Form 982, Part 1 to segregate the total dollar amount of
forgiven debt by exclusion type and capture the informatiOn in IRS's
databases;
2. modify. Form 1099-C to require lenders to identify in a more
useable format. (check boxes or coding, for example) the specific type
of canceled debt and capture the information in IRS's databases;
3. modify the Form 982 and Form 1099-C so that filers disclose the
address of the secured property for which the debt is being forgiven
and capture the information in IRS's databases;
4. determine if available data (including IRS and third-party data)
would allow IRS to better identify whether the forgiven debt is for a
principal residence; and;
5. use the additional data reported on the revised Form 982 and Form
1099-C to assess the extent to which taxpayers are compliant.
To provide better information for paid preparers and taxpayers to
determine eligibility for excluding forgiven mortgage debt from
taxable income, explore and implement readily available options that
would not add significant additional costs, including options such as:
6. make IRS's interactive tool for canceled debt publicly available
for the 2011 filing season;
7. use IRS's telephone software to obtain better information about
why, if at all, taxpayers call IRS with questions about forgiven
mortgage debt;
8. work with tax return preparation software companies to more fully
support complex debt cancellation issues, particularly those related
to forgiven mortgage debts; and;
9. either send notices to taxpayers when a lender files a 1099-C
indicating a forgiven mortgage and the taxpayer does not file a Form
982 or document that the costs or doing so would exceed the benefits.
[End of section]
Appendix II: Comments from the Department of the Treasury:
Department Of The Treasury:
Internal Revenue Service:
Deputy Commissioner:
Washington, D.C. 20224:
August 27 2010:
Mr. James R. White:
Director, Tax Issues:
U.S. Government Accountability Office:
441 G Street, N.W.
Washington, DC 20548:
Dear Mr. White:
We have reviewed your draft report entitled Tax Administration:
Expanded Information Reporting Could Help IRS Address Compliance
Challenges with Forgiven Mortgage Debt. We appreciate your recognition
of the challenges the IRS faces in administering this complicated tax
provision.
We appreciate your suggestions and comments on the possible
improvements the IRS could make in administering the mortgage debt
forgiveness issue through enhanced reporting and compliance measures.
We also appreciate your recognition that there is currently little
data available upon which IRS can measure the extent to which
taxpayers and paid return preparers experience difficulty in complying
with debt forgiveness provisions of the tax Code. The lack of detailed
data also presents challenges in estimating the extent of non-
compliance, and also in determining whether additional resources
should be dedicated to compliance monitoring and/or automated
compliance checks.
While we see significant value in your recommendations, we must first
address the task of acquiring an accurate understanding of the costs
of non-compliance in terms of lost revenue to the Treasury, additional
administrative activities, and burden to the taxpayer and business
communities. After ascertaining the costs and benefits, we will make a
determination on whether or not the analysis supports the recommended
changes to Form 982, Reduction of Tax Attributes Due to Discharge of
Indebtedness (and Section 1082 Basis Adjustment) and Form 1099-C,
Cancellation of Debt; additional compliance processing; and the
provision of supplemental services and education through soft notices.
To determine the extent to which forgiven debts are not being
correctly reported, we will conduct a sample review of Tax Year (TY)
2009 Forms 1040, U.S. Individual Income Tax Return, that were filed
with Form 982. Our review will include a comprehensive analysis of tax
return data and available third-party data necessary to determine the
character of canceled debt reported on the corresponding Forms 1099-C.
In addition to the need to perform a cost benefit analysis, any
programming changes to our automated processing systems and requisite
form layout changes cannot be fully implemented prior to the 2013
filing season (TY 2012 returns). We anticipate our review and analysis
being completed in time to meet this same time frame should the
results support adoption of the recommendations.
Responses to your specific recommendations are enclosed. If you have
any questions, please contact Robin Canady, Director, Strategy and
Finance, Wage and Investment Division, at (404) 338-8801.
Sincerely,
Signed by:
Steven T. Miller:
Enclosure:
[End of letter]
Enclosure:
To enhance IRS's ability to detect noncompliance with mortgage debt
forgiveness provisions,
Recommendation 1:
Modify Form 982, Part 1 to segregate the total dollar amount of
forgiven debt by exclusion type and capture the information in IRS's
databases;
Comment:
We agree with this recommendation, however, implementation will be
dependent on the change being supported by our cost benefit analysis.
If the form is changed, we will also capture the dollar amount entries
for further data analysis.
Recommendation 2:
Modify Form 1099-C to require lenders to identify in a more useable
format (check boxes or coding, for example) the specific type of
canceled debt and capture the information in IRS's databases;
Comment:
We agree with this recommendation, however, implementation will be
dependent on the change being supported by our cost benefit analysis.
If the form is changed, we will also capture the identified debt type
for further data analysis.
Recommendation 3:
Modify the Form 982 and Form 1099-C so that filers disclose the
address of the secured property for which the debt is being forgiven
and capture the information in IRS's databases;
Comment:
We agree with this recommendation, however, implementation will be
dependent on the change being supported by our cost benefit analysis.
If the forms are changed, we will also capture the addresses of the
secured property for further data analysis.
Recommendation 4:
Determine if available data (including IRS and third-party data) would
allow IRS to better identify whether the debt being excluded is for a
principal residence;
Comment:
We agree with this recommendation. We will review a statistical sample
of TY 2009 income tax returns filed with Form 982, Reduction of Tax
Attributes Due to Discharge of Indebtedness (and Section 1082 Basis
Adjustment), and compare to available third-party data to ascertain if
forgiven debt is taxable or qualifies as an exclusion item. The intent
of this review will be to determine the revenue loss to the Treasury
from incorrect taxpayer treatment of canceled debt, and to compare
that information to the additional administrative cost and taxpayer
burden associated with the recommended form and administrative
changes. Commensurate with the review, we will evaluate the benefits
to be derived from recommended form changes and the additional
resulting data that would become available.
Recommendation 5:
Use the additional data reported on the revised Form 982 and Form 1099-
C to assess the extent to which taxpayers are compliant.
Comment:
We agree with this recommendation to use the additional data reported
on the revised Form 982 and Form 1099-C, Cancellation of Debt, to
assess the extent to which taxpayers are compliant. However,
implementation of this recommendation is dependent on the outcome of
our decision on whether or not to make the recommended changes. That
decision, in turn, is dependent on the outcome of the cost benefit
analysis we will perform to assess the extent of lost revenue,
administrative costs, and taxpayer burden associated with the changes.
To provide better information for paid preparers and taxpayers to
determine eligibility for excluding forgiven mortgage debt from
taxable income, explore and implement readily available, low-cost
options to help clarify the tax treatment of forgiven debt, including
options such as:
Recommendation 6:
Make IRS's interactive tool for canceled debt publicly available for
the 2011 filing season;
Comment:
We agree with this recommendation and will deploy the Cancellation of
Debt tax law topic on IRS.gov for the Fiscal Year 2011 filing season.
Recommendation 7:
Use IRS's telephone software to obtain better information about why,
if at all, taxpayers call IRS with questions about forgiven mortgage
debt;
Comment:
We agree with this recommendation. The Information gathered from
Contact Analytics (CA) will be used to ensure Customer Service
Representatives (CSRs) have the information needed to answer questions
on Mortgage Debt Forgiveness successfully. If deficiencies are
identified, clarifications in the form of Internal Revenue Manual
(IRM) procedural updates and Servicewide Electronic Research Program
Alerts will be used to disseminate information to CSRs. The CA will
also be utilized to target specific issues within the Mortgage Debt
Forgiveness program to ensure that the full scope of the program is
covered in the IRM. Success will be measured utilizing targeted
reviews via the Centralized Quality Review System.
Recommendation 8:
Work with software companies to more fully support complex debt
cancellation issues, particularly those related to forgiven mortgage
debts;
Comment:
We agree with this recommendation. The IRS has robust partnerships
with the tax return preparation software industry and uses diverse and
multiple channels to engage them on matters of mutual interest and
importance. The Electronic Tax Administration and Refundable Credits
(ETARC) organization collaborates directly with industry to ensure
they have first hand access to real time information and direct
engagement with subject matter experts. Our most recent monthly
industry call, held in August 2010, addressed mortgage debt
forgiveness. Through this collaboration, IRS engaged industry to
assist us in raising taxpayer awareness among the population that will
most likely be affected by the mortgage debt forgiveness policy, and
who will need to file a Form 982. As a result of this collaboration,
industry agreed to include wherever feasible; interactive worksheets
and other intelligent software features specifically for Form 982
filers to help them calculate what portion of a forgiven mortgage debt
can be excluded from income. The ETARC organization will continue to
provide this vigorous level of direct communications to the tax return
preparation software industry.
Recommendation 9:
Either send notices to taxpayers when a lender files a Form 1099-C
indicating a forgiven mortgage and the taxpayer does not file a Form
982 or document that the costs of doing so would exceed the benefits.
Comment:
We agree with this recommendation. We will either send notices to
taxpayers or document that the costs of doing so exceed the benefit.
Implementation of this recommendation will be dependent on the outcome
of our decision on whether or not to make the recommended changes to
Form 982 and Form 1099-C, which would provide the additional data
needed to initiate a soft notice process for this issue. The decision
to change Form 982 and Form 1099-C is, in turn, dependent on the
outcome of the cost benefit analysis we will perform to assess the
extent of lost revenue, administrative costs, and taxpayer burden
associated with the changes.
[End of section]
Footnotes:
[1] Pub. L. No. 110-142, 121 Stat. 1803 (Dec. 20, 2007) and Pub. L.
No. 110-343, 122 Stat. 3765 (Oct. 3, 2008).
[2] To calculate these revenue effects we added Joint Committee on
Taxation estimates from: Joint Committee on Taxation, Estimated
Revenue Effects of H.R. 3648, The "Mortgage Forgiveness Debt Relief
Act of 2007" as Amended and Passed by the Senate on December 14, 2007,
JCX-118-07 (Washington, D.C.: Dec. 18, 2007), Estimated Budget Effects
of the Tax Provisions Contained in an Amendment in the Nature of a
Substitute to H.R. 1424, Scheduled for Consideration on the Senate
Floor on October 1, 2008, JCX-78-08 (Washington, D.C.: Oct. 1, 2008),
and by adding estimated revenue effects from Estimates of Federal Tax
Expenditures for Fiscal Years 2008-2012, JCS-2-08 (Washington, D.C.:
Oct. 31, 2008), and Estimates of Federal Tax Expenditures for Fiscal
Years 2009-2013, JCS-1-10 (Washington, D.C.: Jan. 11, 2010).
[3] To calculate this number we added revenue loss estimates from the
President's budget requests for fiscal years 2010 and 2011 dated
February 26, 2009, and February 1, 2010, respectively.
[4] National Association of Realtors, Investment and Vacation Home
Buyers Survey, 2010.
[5] GAO, Home Mortgage Interest Deduction: Despite Challenges
Presented by Complex Tax Rules, IRS Could Enhance Enforcement and
Guidance, [hyperlink, http://www.gao.gov/products/GAO-09-769]
(Washington, D.C.: July 29, 2009) and Tax Gap: Actions that Could
Improve Rental Real Estate Reporting Compliance, [hyperlink,
http://www.gao.gov/products/GAO-08-956] (Washington, D.C.: Aug. 28,
2008).
[6] The National Taxpayer Advocate assists taxpayers in resolving
problems with IRS, and is appointed by the Secretary of the Treasury
and reports to the Commissioner of Internal Revenue, although her
views do not necessarily reflect the position of IRS, the Treasury
Department, or the Office of Management and Budget.
[7] We added JCT estimated revenue effects from JCX-118-07, Dec. 18,
2007, and JCX-78-08, Oct. 1, 2008, and from JCS-2-08, Oct. 31, 2008,
and JCS-1-10, Jan. 11, 2010.
[8] We added revenue loss estimates from the President's fiscal years
2010 and 2011 budget requests, Feb. 26, 2009, and Feb. 1, 2010,
respectively.
[9] Realty Trac, Midyear 2010 U.S. Foreclosure Market Report, July 15,
2010.
[10] National Association of Realtors, Investment and Vacation Home
Buyers Survey, 2010.
[11] Freddie Mac, Refinance Report, 1st Quarter 2010, April 28, 2010,
and Alan Greenspan and James Kennedy, Sources and Uses of Equity
Extracted from Homes, Federal Reserve Board 2007-20 (Washington, D.C.:
March 2007).
[12] GAO, Home Mortgage Interest Deduction: Despite Challenges
Presented by Complex Tax Rules, IRS Could Enhance Enforcement and
Guidance, [hyperlink, http://www.gao.gov/products/GAO-09-769]
(Washington, D.C.: July 29, 2009) and Tax Gap: Actions that Could
Improve Rental Real Estate Reporting Compliance, [hyperlink,
http://www.gao.gov/products/GAO-08-956] (Washington, D.C.: Aug. 28,
2008).
[End of section]
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