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Accounting Method Changes for Small Taxpayers with Inventory * Statutory Requirements for Dependency Exemptions * Large Business Examination Program * Timely Refund Claim on Late Return * Avoiding POA Problems * Negotiating Installment Agreements
Editor: Mark
H. Ely, J.D., CPA
Editor’s note: Mr. Ely is the immediate past chair of the AICPA Tax Division's Relations with the IRS Committee. Messrs. VanDeveer and Corbet, and Mdmes. Barnes, Hyde and Gervie, are committee members.
Change of Accounting Method for Small Taxpayers with Inventory under Rev. Proc. 2000-22 Under Rev. Proc. 2000-22, a qualifying small taxpayer with merchandise inventory, that was previously required to account for sales and inventory using the accrual method of accounting, may automatically change to the cash method of accounting and the inventory rules under Sec. 471 will no longer apply. A qualifying small taxpayer is one whose average annual gross receipts for the previous three years (or shorter period if in existence for less than three years) is $1 million or less. For this test, aggregation rules apply to include gross receipts of related parties. Finally, there is a financial statement conformity requirement. The taxpayer must not regularly use any accounting method other than the cash method to determine profit or loss for its financial statements, other financial records and reports to owners, creditors, etc., for the current or prior three tax years (years ending before Dec. 17, 2000 are excluded from this rule). The conformity requirement will not apply, however, if accrual-method reports are prepared by the taxpayer on an isolated basis (e.g., on a one-time basis for a lender). If a taxpayer makes the change to the overall cash method of accounting under Rev. Proc. 2000-22, inventories are not accounted for under the pure cash method. Instead, they must be accounted for in the same manner as nonincidental supplies (i.e., inventoried and deducted only when sold or consumed by the taxpayer). How, then, does the cash method of accounting work with inventories? For inventory that has been paid for by the taxpayer, inventory accounting is customary (i.e., inventory is an asset when on hand and is deducted when sold). But how does a taxpayer account for inventory not paid for by year-end? According to Treasury officials, although the cost recognition rules for nonincidental supplies apply, they must be applied within the cash-basis method of accounting. Accordingly, cost of sales is recognized as of the later of (1) when paid for by the taxpayer or (2) when sold by the taxpayer. In other words, income from the sale of an item can be recognized in a tax year prior to when the cost of sale is deducted. The cost of sale, however, cannot be recognized in a year prior to the year of sale. Also, an inventory item is not recorded until paid for, even though it is on hand at year-end. Accordingly, accounting adjustments to the results of physical inventories must be made. Sole proprietors and Form 3115. A taxpayer applying for the automatic accounting change under Rev. Proc. 2000-22 must file Form 3115, Application for Change in Accounting Method (original with the tax return effecting the change and a signed copy to the national office). For a sole proprietorship, however, the form and instructions are less than clear about who is the "applicant." The first line is "Name of Applicant," but parenthetically notes that the spouse's name is to be included if a joint return is filed. The names of the individual taxpayers, of course, do not identify the sole proprietorship business, but there is nowhere else on the form to distinguish the business that is making the actual application for change. According to Treasury officials, the "applicant" in this case is the sole proprietor, rather than the taxpayer or spouse. The "Name of Applicant" to be entered on the form is the business name of the sole proprietorship, followed by "c/o" and the taxpayer's name (e.g., "ABC Flower Shop, c/o John and Jane Smith"). Further, the sole proprietorship's Federal taxpayer identification number (TIN) should be entered on the form as the applicant's "Identification Number." If, however, the business has no Federal TIN, the taxpayer's Social Security number should be entered. From Barry S. Shipp, CPA, and Carol T. Barnes, CPA, Cole, Evans & Peterson, CPAs, Shreveport, LA
Statutory Requirements for Dependency Exemptions Must Be Met Fully In Miller, 114 TC No. 13, the Tax Court held that a noncustodial parent's permanent divorce order granting him the right to claim his minor children as dependents on his tax return failed to satisfy the signature requirement of Sec. 152(e)(2), because his ex-wife never signed the order and therefore failed to assign him the right to the exemptions. John Lovejoy and his wife Cheryl Miller separated in 1992 and finally divorced in 1993. The state court issued a permanent order of divorce, granting Miller sole custody of the couple's minor children, but also granting Lovejoy the right to claim the children as dependents on his tax returns. The order was signed by Lovejoy, the judge and Miller's attorney (merely as acknowledgement of its form); Miller herself never signed the document. The parties filed their 1993 and 1994 returns consistent with the terms of the order. Lovejoy, however, did not attach Form 8332, Release of Claim to Exemption for Child of Divorced or Separated Parents; instead, he attached the relevant portion of the state court order. In reviewing Sec. 152, the Tax Court drew attention to the necessity of a written declaration signed by the custodial spouse, indicating that the custodial spouse will not claim the children as dependents on the return. The court noted that such a declaration must be made on Form 8332 or a statement conforming to the substance of Form 8332. The court emphasized that satisfying the signature requirement is essential to effectuating the release of the custodial parent's right to the exemption. The court denied Lovejoy the dependency exemptions, reasoning that the permanent orders were not an effective substitute for Form 8332. Because Miller never signed them, they did not confirm her intent to relinquish the dependency exemptions (as required by Sec. 152(e)(2)). In so holding, the court noted that Miller's attorney's signature acknowledging the form of the agreement was insufficient to confirm Miller's intent. Observation: Miller serves as a reminder of the importance of satisfying all applicable provisions of a statute. While substantial compliance may be sufficient for complying with regulatory requirements, it may be insufficient for purposes of complying with statutory requirements. From Mark VanDeveer, CPA, Thatcher & Benson PC, Virginia Beach, VA
Large Business Examination Program The newly formed IRS Large & Mid-Size Business (LMSB) operating division is intended to deal with corporations, S corporations and partnerships with assets of more than $5 million. It also extends coverage to the largest corporate taxpayers that are included in the Coordinated Examination Program (CEP). Prior to the current reorganization, the Service had implemented the Large Business Examination (LBE) program. The LBE program is based on CEP and appears to have migrated into LMSB, although it is not clear at this time that it will still be referred to as the LBE program. The CEP involves procedures and techniques used by the IRS in the examination of approximately 1,500 of the largest U.S. corporations. CEP generally refers to companies with total assets in excess of $250 million. The program is considered highly successful in that it generates large amounts of revenue, ensures that the largest companies are examined on a continuing basis and applies auditing techniques that strive for consistency of treatment of taxpayers with similar issues. CEP also provides the Service with an excellent training vehicle, allowing less experienced revenue agents to work as audit team members. Under the LBE program, many of the CEP procedures and techniques are being applied in the examination of companies with total assets in the $50 to $250 million range that are deemed to warrant team audits. Some of the CEP procedures that are being used include:
Selection for examination under the LBE program will probably involve a lengthy and time-consuming process that will place extraordinary demands on a taxpayer. Many of the companies currently being examined under the LBE program have never been examined before. Some of the problems encountered in LBE audits currently in process include:
It is apparent that, once a company is selected for a team audit under the LBE program, it must devote substantial time and resources to bring about the resolution of the examination. It is extremely important that the taxpayer take control of the audit from the outset, and manage it to achieve a prompt and satisfactory resolution of any issues that may be raised. From Rene M. Corbet, Ernst & Young LLP, New York, NY
Refund Claim Is Timely, Even Though Return Was Filed Late In Weisbart, 7/28/00, the Second Circuit held that an individual's claim for refund in a return filed more than three years late was nevertheless a timely refund claim under Sec. 6511(a). Weisbart received an extension to file his 1991 tax return until Aug. 17, 1992. The return, which showed an overpayment of withholding taxes of $4,867 (and thus served double duty as a claim for refund), was not mailed until Aug. 17, 1995 (three years after the return's extended due date). The IRS did not receive the return until Aug. 21, 1995 and denied the claim on the grounds that it was filed late. Weisbart eventually filed a refund suit. In Weisbart (DC NY 1999), the district court granted summary judgment for the government on the grounds that the refund claim was late and therefore barred under Sec. 6511(b)(2)(A), because it was deemed filed when received by the Service—three years and four days after its due date. Weisbart appealed.
Is a Timely Filed Return Required Under Sec. 6511? As a preliminary matter, the Second Circuit determined that it had an independent obligation to consider whether the district court had properly exercised jurisdiction over the refund claim. Noting that Sec. 6511(a) will deem a refund claim to be timely if it is filed within the later of three years from the time the return is filed or two years from time the tax is paid, the court observed that the "sticking point" in the instant case was the fact that Weisbart's 1991 return was untimely filed. The IRS urged the court to decline to follow Miller, 38 F3d 473 (1994) (in which the Ninth Circuit held that a return had to be timely filed to satisfy Sec. 6511(a)'s three-year deadline), in favor of Rev. Rul. 76-511, which held that a refund claim need only be filed within three years of the filing of a tax return, regardless of the timeliness of that return. Citing several decisions opposite to Miller, the court declined to follow Miller and concluded that a timely filed return is not required to satisfy the three-year rule of Sec. 6511(a). Citing Regs. Sec. 301.6402-3(a)(5), the court further determined that Weisbart's refund claim was timely, as the 1991 return served as both a return and a refund claim within the same document.
Was the Refund Claim Timely Filed? The court then considered whether Weisbart's refund claim, which was filed on Aug. 17, 1995 but not received by the Service until Aug. 21, 1995 (i.e., four days beyond Sec. 6511(a)'s three-year deadline), was nevertheless timely filed under the so-called "mailbox rule" of Sec. 7502. Sec. 7502 deems a return filed on the date it is postmarked rather than the date received by the IRS, if the postmark date falls on or before the "prescribed date" for filing. The Service argued (and the district court agreed) that the "prescribed" period applicable to Weisbart's return should also apply to his refund claim, thus rendering the refund claim untimely because the return was filed late. The Second Circuit observed, however, that such a construction would deprive the refund claim of the benefit of the mailbox rule and was contrary to the IRS's own Regs. Secs. 301.6402-3(a)(5) and 301.7502-1, which, taken together, provide that the applicability of the mailbox rule to a refund claim should be analyzed independently of the timeliness of the tax return, regardless of whether they are within the same document. The court then concluded that, even though the 1991 return was untimely, the refund claim was deemed filed on Aug. 17, 1995, which was within three years of the date Weisbart was deemed to have paid his withholding taxes under the three-year look back rule of Sec. 6511(b)(2)(A) (i.e., Aug. 17, 1992). From Kenneth S. Savell, J.D., LL.M, KPMG LLP, Washington, DC
Avoiding POA Problems with the IRS Practitioners frequently encounter difficulties regarding the processing of Form 2848, Power of Attorney and Declaration of Representative. An Austin Service Center focus group has developed a list of the six most frequent errors encountered in processing power of attorney (POA) forms. The list is provided below in an effort to help practitioners minimize future problems. Form 2848 consists of two parts. Part I is signed by the taxpayer and authorizes the representative to act on behalf of, or receive information with respect to, the taxpayer. Part II (Declaration of Representative) is signed by the representative and indicates the representative's status (attorney, CPA, enrolled agent, etc.).
Failure to Correctly Specify Type of Tax or Specific Matter Item 3 of page 1 of Form 2848 asks for the "type of tax." The IRS cannot process a Form 2848 with a general reference to "all taxes" or "specific issues." The correct reference should be to "income," "estate," "excise" or other specific type of tax as appropriate. If the matter does not fit within one of these recognized categories, the matter should be specifically described. The Service does not enter all POAs into the Centralized Authorization File (CAF) system. The types not recorded in the system include: documents that do not relate to a specific tax year; documents that concern a tax year more than three years in the future; specific issue requests (e.g., a penalty issue); letter ruling requests; or requests to change accounting periods. In such cases, the representative checks a box on Form 2848 and must bring the POA to each meeting with the IRS.
Failure to Specify Title—Business Returns Item 9 of page 2 of Form 2848 requires the signature of the taxpayer(s). Unless the title of the authorized signer is provided, the POA cannot be processed. For corporations, an officer with authority to bind the taxpayer must sign. All partners of a partnership must sign, unless a partner is authorized to act in the partnership's name. (A Tax Matters Partner is authorized to execute Form 2848 on behalf of other partners and the partnership.) For joint returns, both spouses must sign if they are represented by the same individual.
Missing Information—Declaration of Representative Part II, Declaration of Representative, requires the signature, date and designation (CPA, attorney, officer, family member, etc.). Unless all authorized representatives complete all items, the POA will be returned.
Improper Designation of Years or Period Item 3 of page 1 of Form 2848 requires that the tax year or tax period be specified. General references to "all years" and "all periods" cannot be processed. Correct references include, for example, "calendar year 1994 and 1995" or "first, second and third quarters of 1995." Any tax years or periods that have already ended, as well as future periods that end no later than three years after the date the POA is received by the IRS, may be designated.
Missing or Incorrectly Written Identification Numbers Item 1 of page 1 of Form 2848 requests the taxpayer's Social Security number (SSN), individual taxpayer identification number and/or employer identification number. If a joint return is (or will be) filed and both spouses are designating the same representative, both spouses' identification numbers should be entered. If a taxpayer files a joint return but is divorced, the form should be completed using only the taxpayer's SSN. If two SSNs are listed but only one taxpayer signs the form, the POA will be rejected.
Failure to Check Box—Notices and Communications Item 7 on page 2 of Form 2848 states unless box "a," "b" and/or "c" is checked, original notices and other written communication will be sent to the taxpayer and a copy to the first representative only. By checking box "a," the Service will send the first representative the original notice; checking box "b" will allow the second representative to receive copies of notices and communications. If both boxes "a" and "b" are checked, both representatives will receive copies. If box "c" is checked, no communication will be sent to the representative.
Tips to Speed Processing POA forms given to IRS personnel (whether hand-delivered, mailed or transmitted to a service center) will be routed to the applicable service center's CAF unit. Until this form is received and entered by the CAF unit, the POA will not be in the computer system. Practitioners should fax their POAs directly to the CAF unit; a form that is mailed can take upward of 14 to 21 days for input into the CAF system, while a form received via fax is input within 48 hours of receipt. The first time a representative files a POA that is entered in the CAF system, the representative is assigned a nine-digit CAF identification number. This number must be included on that and all future POA forms.
CAF Unit Fax Numbers The Service has the capability to access POA information from a universally accessible database. Thus, taxpayer representatives may file Form 2848 at any service center, regardless of their location. The fax numbers are:
From Nancy K. Hyde, Onstott, Craddick & Hyde CPAs, Inc., Oklahoma City, OK
Negotiating Installment Agreements with the IRS Collection Division A task frequently faced in representing clients before the IRS Collection Division is negotiating an installment agreement, under which monthly payments are made against an accrued tax liability, free of the threat of levies and seizures. Despite the Service's more mechanical application of national and local standards for "allowable" personal living expenses, there is still room for effective advocacy. In addition, the Internal Revenue Service Restructuring and Reform Act of 1998 (IRSRRA '98) made changes to the negotiation and legal consequences of installment agreements, and places greater emphasis on their use.
Identifying the Objective Except for certain limited cases involving small balances, the IRS Collection Division will not accept a monthly payment agreement unless there is no alternative. In these cases, the task becomes getting the best possible deal, which requires an understanding of the client's objectives. For some, the goal is full payment of the accrued liabilities as quickly as possible (to minimize interest and late payment penalties). Others, however, have created tax debts so large that full payment is just not possible; these taxpayers must look to the expiration of the statute of limitations (SOL) on collection, an offer in compromise or bankruptcy. For them, an installment agreement is an interim solution, and the objective is negotiating the smallest monthly payment the Service will accept. The IRS simply wants the largest payment the taxpayer can afford.
Current Compliance A prerequisite to any installment agreement is "current compliance." This means that all required returns must be filed, and the taxpayer has rejoined the "pay-as-you-go" system. For business taxpayers, the Service will demand proof that current payroll taxes are being deposited on a timely basis. For individuals, there must be evidence of adequate withholding or estimated tax payments for the current tax year. A taxpayer who is piling new liabilities on top of old ones is "pyramiding," in IRS-speak. For business taxpayers, the pyramiding of withholding taxes may reduce the chances for relief from levies or seizures.
Collection Information Statement For installment agreements, the key IRS forms are Form 433-A, Collection Information Statement for Individuals, and Form 433-B, Collection Information Statement for Businesses; self-employed taxpayers must use both forms. The best way to help a client with a tax collection problem is to assist in completing these forms accurately, and with complete supporting documentation. Every entry must be correct and substantiated, not only because the form is signed under penalties of perjury, but also because an incomplete or inaccurate form may damage the practitioner's credibility with the Revenue Officer.
Sources of Information For new clients, it is helpful to obtain copies of any collection information statements previously filed from the Revenue Officer handling the case. If no Revenue Officer has been assigned, the practitioner should consider filing a request with the District Disclosure Officer under the Freedom of Information Act. Also, in all new cases, the practitioner should ask the Service for complete account transcripts for all relevant taxes and tax periods. These will provide details of all IRS transactions for each tax period, including assessments, penalties, interest, payments, refunds and offsets, lien filing dates, SOL and a host of other valuable information.
Assets Forms 433-A and 433-B include balance sheets, requiring a taxpayer to list all assets, regardless of their nature or where they may be located. (If a practitioner believes a given asset is beyond the Service's legal reach, has no value or is subject to some prior encumbrance, the asset should be listed and information supporting this position should be provided.) Before discussing monthly payments, the Revenue Officer will first address selling or borrowing against assets. Generally, an installment agreement is allowed only if there is no ability to liquidate or borrow against assets to pay or reduce the tax debt. The IRS's Collecting Contact Handbook gives explicit instructions to Revenue Officers about how to approach these issues:
By being aware of what the Service may do, a practitioner can be prepared to meet these questions and demands in a manner designed to achieve the most favorable result for the client. For assets, there are two critical issues: ownership and valuation. The form of ownership is particularly important when assets are jointly held but only one spouse is liable for the tax. Many states offer a high degree of protection for "tenants by the entirety" property. In such states, no creditor (including the IRS) can generally reach such property to satisfy a spouse's separate debt. Determining valuation offers many opportunities for vigorous advocacy. It is important that the Form 433-A or 433-B and accompanying materials adequately and fairly present the net amount that may be realized from a sale of a client's assets with proper allowance for expenses of sale, taxes and other costs. For example, the sale of securities may result in a current-period income tax, which would reduce the net after-tax proceeds. A premature withdrawal from an IRA or qualified pension plan may result in a penalty, in addition to a current-period tax. The sale of a client's house could require closing and brokerage costs, again reducing the net realizable value. (The costs attendant to moving and securing new housing are also relevant in presenting the net amount a client may actually realize from the sale of a house.)
Income and Expenses Having demonstrated that a client is in current compliance and having addressed the issue of selling or borrowing against assets, the practitioner can next address the client's monthly income and expenses to arrive at an appropriate monthly installment payment. This discussion will be limited by the standardized expenditure allowances that the Service has developed to obtain more uniformity in collection cases. The IRS essentially divides expenditures into "necessary expenses" and "conditional expenses." The IRS publishes tables, based on income level and family size, for three categories of necessary expenditures: "national standard" expenses, housing and utilities expenses and transportation expenses. The Service's Collecting Contact Handbook contains the following description of these expense categories:
In computing ability to pay, necessary expenses are allowed whether or not the proposed agreement would result in full payment in three years. Conditional expenses, however, are allowed only if the tax liability can be paid in full within three years. Although it is easier to rigidly adhere to the national and local standards, Revenue Officers may allow excess necessary or conditional expenses for the first year of an agreement. This permits a reasonable "adjustment period" to bring expenses within the standards. Revenue Officers will seldom volunteer this one-year relief period. It is incumbent on the practitioner to argue for the application of this rule if it can benefit the client. Many expenses are "necessary," even though they may fall outside the lists of expenditures covered by the IRS's standards. While the standards are designed to achieve more uniformity, they do not impose a rigid, mechanical cap; "excess" expenses may be allowed if the taxpayer can provide substantiation and justification. Examples of necessary expenditures that fall outside of the national and local standards include:
Form 433-A has lines labeled for some of these items, but others might easily be overlooked if the practitioner simply follows the form without checking the IRS's pronouncements. Finally, practitioners should be aware of the fact that the national and local standards change periodically. Merely following the instructions issued with Form 433-A does not guarantee the latest numbers. The most recent standards can be downloaded from the Service's Website (www.irs.ustreas.gov/prod/ind_info/coll_stds). Impact of IRSRRA '98 on Agreements The IRSRRA '98 included several provisions that have already had an impact on the negotiation and use of installment agreements. Perhaps the most important change is a greatly expanded right to appeal threatened collection actions, thereby providing an administrative forum in which to argue that an installment agreement should be used as an alternative to enforced collection action.
Availability of Installment Agreements in Small Cases The IRSRRA '98 required the IRS to expand its previously existing program of granting simplified installment agreements for small cases. There are now two kinds of simplified agreements: the "guaranteed" agreement and the "streamlined" agreement. The "guaranteed agreement" is the Service's response to Sec. 6159(c). The IRS will grant a guaranteed installment payment agreement if (and only if) the taxpayer:
Such a guaranteed agreement can be obtained by contacting the Service or by filing a Form 9465, Installment Agreement Request. The IRS has also adopted an "interactive installment payment process," under which guaranteed installment agreements in small cases can be implemented directly over the Internet through the Service's Website; see www.irs.ustreas.gov/ind_info/coll_stds/who_can_use.html . The "streamlined" installment agreement is an expanded version of an IRS policy that was in place prior to the IRSRRA '98. Such agreements may be approved if:
The taxpayer must otherwise be in current compliance. In addition, streamlined agreements are not available if the liabilities in question are withholding taxes for a business taxpayer still in business. A streamlined agreement can be obtained by telephone, by correspondence or through the Revenue Officer assigned to the case.
Reduction in Late Payment Penalty The IRSRRA '98 also reduced the Sec. 6651 late payment penalty while a taxpayer is under an installment agreement. Clients are often shocked to find that the Service continues to assess interest and the one-half of one percent-per-month late payment penalty, even after they have entered into an installment agreement. Instead of eliminating the penalty, however, Congress chose to reduce it to one-quarter of one percent for any month during which an installment agreement is in place. This modest penalty relief applies only to individuals, and only if the original tax return was filed on time.
SOL Extensions The IRSRRA '98 makes changes concerning extensions of the SOL on collection. Previously, entering into an installment agreement did not automatically extend the 10-year SOL on collection. However, the Revenue Officer often demanded that the taxpayer "voluntarily" extend the SOL to a date far in the future before an agreement would be granted. In general, the IRSRRA '98 eliminates the IRS's ability to demand such voluntary extensions. For an installment agreement, however, the Service retains the right to ask for an extension for the time it would take to achieve full payment beyond the normal 10-year SOL expiration date, plus 90 days.
Administrative Appeal of Proposed Collection Action Although the procedural changes described above are helpful, the greatest impact of the IRSRRA '98 on the use of installment agreements is the opportunity the new law provides to appeal proposed collection actions. (This provision has already had the desired effect of forcing the Service to abandon more aggressive collection techniques in favor of installment agreements.) Under the IRSRRA '98, the IRS cannot levy against property unless it has first provided the taxpayer with a "Notice of Intent to Levy," similar to that which was previously required by Sec. 6331(d). Subject to certain exceptions, no levy can occur until 30 days after issuance of such a notice. During the 30-day period, the taxpayer may demand a pre-levy "Collection Due Process" (CDP) hearing before the IRS Appeals Office. Sec. 6330 lists issues that may be raised at this hearing:
Given the ability to more easily appeal threatened levy actions, many more taxpayers are taking their cases to Appeals. And at those hearings, taxpayers' representatives understandably argue that installment agreements provide an effective, reasonable and appropriate alternative to the seizure of their clients' assets. The expanded right to appeal proposed collection actions also applies to the threatened termination of an installment agreement. The Service may terminate an agreement when it finds that a taxpayer has failed to pay an installment payment when due, failed to pay another tax liability when due, failed to provide updated financial information on request or secured the agreement by providing information that was inaccurate or incomplete. (Generally, installment agreements will not be defaulted for a taxpayer's failure to make estimated tax payments or tax deposits, or a failure to file another return when due.) A taxpayer must be given 30-days' notice in writing before an installment agreement is terminated, and no levies may be served until 90 days after the notice is provided. Within the 30-day period, the agreement can be reinstated if the taxpayer cures the default. A new collection information statement may be required (unless the case meets the criteria for "guaranteed" or "streamlined" agreements previously discussed). In addition, taxpayers may appeal defaults and terminations of installment agreements. No levy action may be taken while the taxpayer's case is awaiting consideration before Appeals.
Conclusion Unfortunately, many taxpayers are simply unable to pay their taxes in full, even by selling or borrowing against their assets. These taxpayers are forced to look to future cashflow to resolve their tax problems. With knowledgeable and creative representation, practitioners can help such clients to address their tax responsibilities through reasonable and appropriate monthly payment agreements. From Burton J. Haynes, J.D., MBA, CPA, Burton J. Haynes, P.C., Burke, VA, and Mary Lou Gervie, CPA, CFE, Watkins, Meegan, Drury & Company, L.L.C., Bethesda, MD |
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