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BOE FY 2012113 Bills - Tl1IIllor Billa 9f'Iacu>d
BOE FY 2012113 BUDGET CHANGE PROPOSAL OVERVIEW
(as of 10113111 - in OOO's)
BCP'S - Chaptared Bills - Tl1IIllor Billa
I".... u'm"'y Bill (AB) 165 - Use Tu Nuus:
BIll (AS) 155 ru~1s amendments to S~on 62a3 Ihat
made by ASxl 28, 9f'Iacu>d on June 28, WI I , and
esse~lI~ po.sIpOnes the operntl'olll dalB un\ll Septamber IS.
20'2. d federalleglSl<I1ion Is not en3C1ecl O1at anables st811!S 10
impose II use talC colledJon oblrgation 1>/'1 ou1-of-S1BIe re\8'18~
nexus In Callfoml9. AS ISS Inae.ases 018 Qlmulatlve
tangible personal propet1y 10 $1 mIllion. ~ it bealmes
under Ihe ClfOJmslBI'ce5 deoalbed above. This
2B.3
replaar.; BOE's A8~ I 28 proposal presenteG 10 ttle
In Seplembe1'
DiU requires ()uslnes.ses en9ll9lnllin online sales (0 pay sales
This Dill dehn6$ a -retailer engaged In business in this $l8tePurp<l6es of imposing a usa !all IXlllectJon o~Jgatlon on IhaI
10 include aoy ,etailer !!Ia' has su~ual n8X\l, W11h
for purpOses oIlhe Ccmrnen:e Clause 01 the Un~ed
eo.'S1~lll1l"n and any retailer upon whom laderal .......
Ih is S181e 10 impOse a use tax colleclion dilly.
TObU:~
53,180
GF: $2,083
R; $1,097
30.7
$3,197
GF: S2,094
R: 51,103
_____ _~~~__~________~~________;-__~__~~~~__~______~__~______-;
_a/ BOE has nol projected revenues allhis lime.
Page 1 of 1
STATE OF CALIFORNIA
Budget Change Proposal - Cover Sheet
DF-46 (REV 05111)
Fiscal Year
2012-13
BCP No.
6
Org. Code
0860
Department
State Board of Equalization
Priority No.
zt
~
Program
30 Sales and Use Tax Program
Element
All Elements
Component
N/A
Proposal Title
AB 155: Use Tax Nexus
Proposal Summary
Assembly Bill (AB) 155 (Chapter 313, Statutes of 2011) both delays and amends provisions of ABx1 28 (Chapter
7, Statutes of 2011) which was enacted as part of the 2011-12 California l3udget.
BOE is requesting funding and resources needed to implement the proVisions,pf AB 155.
• $3.2 million and 28.3 positions in FY 2012-13
• $3.2 million and 30.7 positions in FY 2013-14
• $3.6 million and 35.1 positions in FY 2014-15
Requires Legislation
Yes
~ No
Code Section(s) to be Added/Amended/Repealed
Does this BCP contain information technology (IT)
components? D Yes
~ No
If yes, departmental Chief Information Officer must.sign.
Department CIO
D
Date
For IT requests, specify the date a Special Project Report (SPR) or Feasibility Study Report (FSR) was
approved by the California Technology Agency, or previously by the Department of Finance.
D FSR
D SPR
..... Proj~ct No.
Date:
If proposal affects another department, does other department concur with proposal?
0 Yes ~ No
Attach comments of affected depclrtJ:nent, .~igne.d and dated by the department director or designee.
Date
Chief Financial
mt. Division
Date
Executive Director
Additional Review:
BCPType:
PPBA
D
Capital Outlay
o Policy
D
ITCU
D
FSCU
D
OSAE
D
CALSTARS
D
Technology Agency
o Workload Budget per Government Code 13308.05
!
Date submitted to the Legislature
BCP No.6
State Board of Equalization
Fiscal Year 2012-13
BOARD OF EQUALIZATION - AB 155 USE TAX NEXUS
A. Proposal Summary
Assembly Bill (AB) 155 both delays and amends provisions of ABx1 28, which was enacted as
part of the 2011-12 California Budget.
Specifically, AB 155:
•
Repeals amendments to Section 6203 that were made by AB~128, enacted on June 28,
2011, and postpones the operative date of ABx1 28 until Septe.~ber 15, 2012 if federal
legislation is not enacted that enables California to impOse a usefax~ollection obligation
"':' .
on out-of-state retailers without nexus in California.
•
Provides that if federal legislation is enacted. on or before July 31, 20Y2/ put California
does not enact legislation on or before Septemper 14,2012, to conformJo that federal
legislation (by adopting a streamlined sales ahd use tax system or other legislation
which conforms to the newly enacted federal law), then the provisions of ABx1 28 will
revive effective January 1, 2013 (rather than September 15, 2012).
•
Increases the safe harbor threshold for small retailers,limiting the affiliate nexus
provision to cumulative sales of tangible personc:ll property in excess of $1 million, if it
becomes operative under the circumstances described above. The affiliate nexus
provision in ABx1 ..28app'lied to retaile·rs : having cuniulative sales of tangible personal
property to CalifC)d1ia purCha.sers in excess of $500,000.
.°
.
~ .~.
•
th~
Amends section 6203 of
Revenue and ' Taxation Code to expand the definition of a
"retailer engaged in business in this state."' The bill provides that a retailer engaged in
busirl~ :in Ca.lifornia jn(;ludes any· retailer that has substantial nexus with this state for
purphsesaHh~ ,:c9mmerce <;:Iause of the US Constitution and any retailer upon whom
federal law peifrltfSJhis stat~ to impose a use tax collection duty, with examples of
<:application and spebiri~ exclusions .
.
•
1\
";.
"::""
.
" ,
Expahds the use ta~' registration requirements to certain out-of-state retailers that
previously may not h~ve been required to collect use tax on sales made to their
Californiacustomers,including transactions conducted through mail order, telephone
orders, or via the Internet.
If provisions of AB 155 are implemented, this bill generally provides that a "retailer engaged in
business in this state" includes, under certain circumstances , but is not limited to:
•
Certain retailers that are members of a commonly-controlled group and members of a
combined reporting group that includes another member of the retailer's commonly
controlled group that, pursuant to an agreement with or in cooperation with the retailer,
performs services in this state in connection with tangible personal property to be sold by
the retailer, including design and development of tangible personal property sold by the
retailer, or the solicitation of sales of tangible personal property.
BCP No.6
•
Certain retailers that have entered into an agreement under which a person in this state,
for a commission or other consideration, refers potential purchasers of tangible personal
property to the retailer.
Currently, proposals exist in Congress to streamline sales taxes across the fifty states. The
bills, S. 1452 by Senator Dick Durbin (D-Illinois), and H.R. 2701 by Representative John
Conyers (D-MI), identical and both known as the "Main Street Fairness Act," would provide
uniform definitions concerning sales and use taxes to states participating in the Streamlined
Sales and Use Tax Agreement, and would provide states accepting membership with the
authority to collect sales tax whether or not sellers have a substantial physical presence in the
states. At this time federal legislation has not been enacted and it is unknown whether or not
any possibly enacted legislation will be similar to the proposed Main Street Fairness Acts. It is
also unclear if a federal mandate will apply to all interstate sales without any "safe harbor"
provisions.
-::/:."
:-::;-::. ...
For the purposes of this BCP, BOE will use the assum.ptions outlined:in AB 155 utilizing an
implementation date of September 15th , 2012. For vafl6Ds reasons, it is\difficult to provide a
reliable estimate of revenues associated with this measure. In order to impleM~nt AB 155, BOE
requests funding of $3.2 million and 28.3 positiqn~ in FY 2012-13, and $3.2:n")f.llic)!1 and 30.7
positions in FY 2013-14, and $3.6 million and 35~1~itionsit1FY 2014-15 toilllplement the
provisions of AB 155.
.' . ....
. ... .
..
B. Background/History
".
-: .
....:: .. <.
Under constitutional law, states lack jurisdiction toreqtitreout-of-state retailers to collect a sales
or use tax when the retailer has no substantialnexusWlththe<tCiXing state. In 1992 the Supreme
Court issued an opinion in Quill Corporation v. North Dakota (1992) 504 U.S. 298, holding that a
physical presence is nqtreqLiiredJor due process concerns, but rather only minimum contacts
with the taxing stat~.~;thus, wheila mail-order>business purposefully directs its activities at
residents of the taxrngs~t!3, the Oue Process Clal.lsedoes not prohibit the state's requiring the
retailer to collect the state's use tax; However, the Court further held that in order to survive a
Commerce Clc3U~!3 challenge, a retailer mListhave substantial nexus in the taxing state before
that state sarft~qLilreth~ retalleH9 collect
tax.
Hsuse
Sincem~late 1990s, ori11®shopplng'hS3s taken off as an increasing number of businesses and
consumers purchase increa~1rgly div~tsified products on the Internet. That, combined with the
states' probl~,s with impos'in9 a use tax collection requirement on many out-of-state retailers,
has prompted many states to seek new ways to enforce their use tax laws (every state that has
a sales tax irnpos~s the useiax). In California, for example, ABx4 18 was enacted in 2009 to
require all businessesthathave gross receipts from business operations of at least $100,000
annually and that aren.Otalready required to be registered with the Board of Equalization (BOE)
to register and file an annual use tax return to report and pay the applicable use tax on their
untaxed purchases. As of May 31, 2011, the BOE has collected over $65 million in revenue
associated with this provision.
With the increasing numbers of businesses and consumers shopping online, in the early 2000s
the BOE began focusing on additional needed legislative changes to encourage voluntary
compliance, and to provide a cost-effective outreach and education effort to a wider audience of
purchasers,
Page 3 of 19
BCP No.6
C. State Level Considerations
BOE collects taxes and fees that provide approximately 35.6 percent of the annual revenue for
state government and essential funding for counties, cities, and special districts. The BOE
administers the state's sales and use, fuel, alcohol, tobacco, and other taxes and collects fees
that fund specific state programs, which, in fiscal year 2009-10, produced $50.7 billion for
education, public safety, transportation, housing, health services, social services, and natural
resource management. This proposal addresses the Legislature's intent to coliect revenues
related to the sales of natural gas in order to fund low-income public and energy
efficiency/conservation programs.
This proposal addresses the Legislature's intent to reduce the sales and use tax gap and is
consistent with the BOE's strategic plan. A December 2010 BOE estimate of uncollected use
tax reveals that about $1.145 billion goes unpaid annually ($795 million in uncollected use tax
from California consumers; $350 million from businesses).. The . e~jm..ate indicates that the
unpaid use tax liability owed by the average California househ.old is $61 per year and $102 per
year for each California business. Specifically, this proposal conforms to four of the five BOE
Strategic Plan Goals:
•
•
•
•
Maximize Voluntary Compliance in BOE's PrOgrams
Improve the Efficiency of BOE's Tax and Fee Programs
Improve the BOE's Organizational Effidency
Create an Expanded and Responsive Infrastructure
D. Justification
AB 155 expands the definition of "retailers engaged in business" in California.
The
implementation of this 'expansion willi impact numerous BOE Departments. The change
resulting from this bill ipherently prompts uncerh(inty and questions for many businesses that
have not prev~ ously condu.cted bus,iness im Califomia. Additionally, this issue continues to
receilve national attention. As with -all of our programs, BOE strives to seamlessly integrate new
taxpa,yers with the inten.t to lieceive a high level of voluntary compliance with their reporting
requ'irements.· bue to the highry sensitive topics of nexus and taxation present in this bill, it will
be necessary to have staff avaifabJe to h~ndle questions, provide guidance and information to
these busiresses and to provide ol!Ureach andi advertise the provisions of this bill to groups
generally not contacted in fhe normal course ot this agency's business.
BOE expects upwards ot 2,OOP n.ew use ta,x accounts to be registered under the provisions of
this bill. Data minif),g and 91)dit staff are needed to identify those out-ot-state accounts that are
required to be registered, contact the businesses to ensure registration occurs and then
incoliporate those accoUnts and 1heir reporting praotices into BOE databases. Audit presence
assists in ensuring voluntary compliance. To properly implement and administer the provisions
of AB 155, adequate staffing is necessary.
The resources requested in this proposal allow the BOE to continue to provide high quality
services to taxpayers while protecting General Fund revenues. Resources are needed in the
first year to participate in discussions at the State and Federal level regarding potential federal
legislation, draft regulations, answer incoming questions from taxpayers, retailers, tax
practitioners, etc. and to provide outreach for these groups to explain the new laws. In addition,
resources are needed in FY 2013-14 to address litigation, appeals and settlements as a result
of the newly enacted legislation. Additional resources are needed in FY 2014-15 to audit newly
registered out of state retailers. By FY 2014-15, it is anticipated that the call volume will
Page 4 of 19
BCP No.6
decrease, so 7.0 positions supporting the Taxpayer Information Section will expire.
following is a summary of the requested positions:
The
.-
BY
2012-13
BY+1
2013-14
BY+2
2014-15
BY+3
2015-16
BY+4
2016-17
Business Taxes Specialist III
1.0
1.0
1.0
1.0
Business Taxes Specialist II
0.6
1.0
1.0
1,0
1.0
1.0
2.0
2.0
2.0
2.0
2.0
2.0
1.0
1.0
1.0
7.0
7.0
7.0
Classifications
Sales and Use Tax Department
Tax Policy Division
Field Offices
Business Taxes Specialist I
._-_.Associate Tax Auditor
Office Technician
Total Sales and Use Tax Department
1.8
, 2;0
Legal Department
i
:..
Tax and Fee Division
I
.,'
..~
1.0
1.0
1,0
1.0
1.0
1.0
U)
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0,5
'2.0 '
4.0
4.0
4.0
4.0
12.0
12.0
12.0
6.0
6.0
2.0
2.0
2.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
Business Taxes Specialist I
4.0
4.0
4.0
4,0
4.0
Audio Visual Specialist
1.0
1.0
1.0
1,0
1.0
21.0
21.0
21.0
14.0
14.0
2.0
2,0
1,0
1.0
1,0
2.0
2.0
1.0
1.0
1.0
1.5
1.7
2.1
2.1
2.1
28.3
30.7
35.1
28.1
28.1
Tax Counsel
III (Specialist)
,
.. .. __ ._
Litigation Division
Staff Services Analyst
I
Tax Counsel III (Specialist)
"
'
'.;- ::
Appeals Division
I
Tax Counsel III (Specialist)
I
Settlement and Taxpayer SeNlces Pivision
Tax Counsel III (Specialist)
,
'to -,'I,
Total Legal Department
External Affairs Department .
Customer Ser,liic(i 8. ·plip,lisNng Di'{ision
'
'
Tax TeChnician
II
..
..
'
Tax 'fethnician
III
',', . ' .
...
Supervising,T ax Tech III
-
..
Business Taxei Rep
,..
~
Outreach Services pivision
Total External Affairs Department
Executive Department
Legislative & Research Division
Business Taxes Specialist III
Total Executive Department
Temp Help
TOTAL PERSONNEL YEARS
.
Page 5 of 19
BCP NO.6
Position descriptions and workload justification can be found in EXHIBIT I (Pages 7-16).
E. Outcomes and Accountability
This proposal enables the BOE to implement the provisions of AB 155. The outcome of the
increased staffing will be measured by increases in permitted businesses, revenue generated
by the new registrations and the audit leads gathered. The data collected from these activities
will be captured for future revenue estimation and reporting. Absent funding or additional
legislation, this proposal will be implemented September 15, 2013.
F. Implementation Plan
The estimated implementation timetable assumes a FY 2012-13 start date as follows:
July 2012 - June 2013
July 2013 -On-going
•
Get infrastructure in place (pes,
printers. phones, cubicles, etc,) for
staff.
•
Permanenlly establish and fiii
remaining positions identified
in this proposal.
•
•
•
Hire staff.
•
Train staff.
•
Train newly hired staff.
Begin integration of newly hired
staff with existing staff and training
workload.
Assign workload commensurate
with staff level and experience.
G. Supplemental Information
[8] None
o Facility/Capital Costs
o Equipment
H. Recommendation
Approve the positions as proposed.
I.
Fiscal Detail
j- -
See attached fisca~ detail schedules (pages 17-19).
Page 6 of 19
o Contracts
o
Other
BCP No.6
EXHIBIT I
Position Description and Workload Justification
SALES AND USE TAX DEPARTMENT (SUTD)
1.0 Business Taxes Specialist III (BTS III)
The Streamlined Sales Project (SSTP) was established in March 2000 and was created by state
governments to simplify and modernize sales and use tax collection and administration. In
October 2003, the Governor approved S8 157 (Chapter 702, Statutes of 2003), enabling
California to join the SSTP effort as a voting participant. The same legislation also created a
Board of Governance (BOG) to represent California in all meetings concerning the new tax
system. The BOG is authorized to vote on behalf of California and to represent the State in all
matters pertaining to the Streamlined Sales and Use Tax Agreement (SSUTA). The BOG
establishes and directs the workload goals and objectives associated with California's
participation in the SSTP. The ultimate goal of this work is to collect the currently lost use tax
from out-of-state retailers; thereby enhancing California's revenue generating ability.
The BTS III position will serve as the coordinator for' California's partiCipation in the SSTP.
Under the direction of the Chief, Tax Policy Division, the BTS 1111 serves a~ the highest level
technical advisor to Board Members and their staff on matters concerning the SSTP. As the
BOG representative at the mUlti-state SSTP implement"ing state and conforming state meetings,
the BTS III has direct contact with members of the California Legislature in concert with the
Legislative Division, nationwide high-ranking public Officials, and national, state, and local
government and business groups. The BTS I1III directs the preparation of an unprecedented,
independent study of the SSUTA as it compares California's Sales and Use Tax Law, policy and
procedures relating to specific industries, polit'ically sensitive administration issues, legislation,
and its potential impact on the state and local governments and ,qusinesses.
The BTS 111 is responsible for coordinating withfn the Sales and Use Tax Department (SUTD) in
presenting reports 0'1 the status of California's' involvement in the SSTP to the BOG and the
State Legislative Committees. Th~ -'8TS 11111 will also coordinate drafting legislation for the SUTD
to conform the Sales and Use lax Law to the SSUTA. The BTS III is the primary management
support and lead role in SUTO in support of the Legislative Division for the BOG and is
responsible for coordinatinQl its activities, such as setting up public meetings, compiling and
distributing lnfoffilalion ,r~quests, i\lrld identifying and establishing workload goals .
....
..
~:,
,
......
. Work.l oad Detail
TIme
Measure
nme Measure
Ongoing Activities
nme Per
Classification
Business T ~es
Specialist III (BTS
III)
Comprehensive Analysis: SSUTA Sedion
Analysis;, Review and Address Public
Comment; 'Identify Impact Study Options;
Complete Impact Study: Prepare Analysis,
Revenue Estimate and Impact Study for BOG
H
General Assignments: Analysis of
H
amendments to the SSUTA, Attending SSTP
meetings. prepare SSTP meeting summaries.
SSTP surveys and requests for Information,
outslde presentations, quarterly BOG reports.
BOG meeting coordination, public Information
meetings, administtative Bnd legal assistance
AdminIstration: Training and Management
H
SupporUlead
Total BTS III Hours
Total BTS III positions requested (1,800 hours/position
Page 7 of 19
Occ;ulTences
Per Year
1.080
1
Total Hours
(TIme per Occ.
x Occ . Per yr)
1,080
460
1
MSO
260
1
260
I H:r Houfll Occurrence
Activity
1,800
1.0
BCP NO.6
1.0 Business Taxes Specialist II (BTS II)
The BTS II position performing data analysis for SUTD will be utilized to identify those out-ofstate retailers required to register, which indudes researching and examining data sources and
SEC filings for mergers and acquisitions to determine if new nexus is created. The BTS II will
create and maintain a database of these out-of-state sellers, work with other states on
registration efforts and internet outreach efforts to increase voluntary compliance. Audit leads
will also be created and identified accounts will be evaluated for audit selection. The BTS II is
expected to have extensive computer application knowledge including ACL and Name Search
training to effectively utilize matching software and to handle voluminous amounts of data, This
position will also be involved with internet outreach efforts.
Workload Detail
Time Measure
Ongoing Activities
Percenta~ ·of
Occumnces P'e r
Time Pe'r
Yea,
Classification
Activity
H=Hours
8TSII
Identify and register internet
sellers.
Outreach to other states and
internet sellers to increase
voluntary compliance.
500
25%
500
25%
Maintenance of internet sellers
data base.
Aud~ selection activities lor
Internet sellers.
Reporting activilies relaled to
program performance and
compliance.
400
20%
~~tlvlty
~
II
,500
400
I
I
300
15%
300
15%
300
-
"-
300
2,000
1.1
Total BrS II positions requested (1.800 hours per position)
---.
',".
500
",,'"
Total BTS II Hours
,
Total
Hours
-
.'
:
2.0 Business Taxes Spee.~Hst 1 (EnS I) Out-of..stilte District field positions
The two BTS Is 'JIjili be utilized to prepare audit reports, conduct the most difficult and complex
audits, typicalty'c'onsisting of 'the largest corPorations in the United States, including use of
speCialized audit pr6'~l,Ires and. techniques to address the increase in the number of
register.~d out-of-state refarters and the associated audit workload. The BTS I is expected to
work' with :iimited supervision and to lead and review the work of lower level auditor staff. BTS I
auditors m~y .;plso be involVed in the appeals process related to their complex audits or field
billing orders inCluding petitio.ns for redetermination and hearings. The table below provides the
estimated workload for this poSition.
Workload Detail
. 'TIme Measure
Classification
Business Taxes
Specialist I (BrS I)
field auditor
Activity
Conduct BTS I level audits and
prepare audit reports PJ
Ongoing Activities
Time Measure
H = Hours
H
TIme Per
o.ccurrences
Occurrence
Per Year
216
14
Total Hours
(Time per Oee.
)/. Oec. Per yr)
3,024
3,024
Total BTS I Hours
Total BTS I Positions Requested (1,400 Hours Per
2.16
Position field auditors)
(3) The average was compiled from oul-of-slate statistics for Ihe last three fiscal years (Fiscal Year End 2008, 2009 & 2010).
"Audits" include deficiencies. refunds, and no change audits. The number of audits selected is expected to increase by
approximately 40 audils per year (26 audits at the ATA level and 14 al the BrS I level.) The average time to complete Ihe
BTS I level audits is approximately 216 hours per audit.
Page 8 of 19
BCP No.6
2.0 Associate Tax Auditors (ATA) Out-of-State District field positions
ATAs will be utilized to conduct sales and use tax audits, prepare audit reports, and conduct
specialized audit procedures and techniques to address the out-of-state audit workload based
on approximately 2,000 new, out-of-state registered retailers. Responsibilities include
examining taxpayers' books and records and determining the appropriate amount of tax due,
determining the appropriate test or statistical sampling methodology, preparing working papers
to support audit findings, issuing billings as needed, and explaining audit findings to taxpayers
or their representatives. A TAs will also be responsible for investigating referrals generated from
these new retailers. The auditor may be involved in the appeals process related to audits or
field billing orders including petitions for redetermination and hearings. The table below
provides the estimated workload for these positions.
.
Workload Detail
Time Measure
Time Measure
Classification
Assoc. Tax Auditor
(ATA)
H: Hours
Activity
H
Conduct ATA level audits,
Investigate and audit referrals, and
prepare audit reports including
_.L ,.
related activities It)
Total ATA Hours
Total ATA Positions Requested 11,400 Hours Per
Position)
,','
Ongoing ActivIties
. ..
Oci:urrences
Time Per
' ~iirY9ar
Occ':'mtnce
122
26
Total Hours
3,172.0
3,172.0
2.2
(1) The average was compiled from out-of· state statistics for the last three fiscal years (Fiscal Year End 2008,
2009 & 2010) based upon audits performed by ATAs . "Audits· ,include deficiencies, refunds, and no
change audits. The number of audits selected ;~ expected to incre$S~ by ~pproximately 40 audits per
year (26 audits at the ATA level and 14 at the 8TS I level.) The average lim'e to complete these audits is
approximately 122 hours per audit.
'
1.0 Office Technician (OT) Out-ot~Sta,te Distrlc~ field position
OTs perform typical clerical revenue supporting functions related to the registration of out-ofstate taxpayers. These clerical functions include 'filing, copying, answering phones, attendance
coordination, maintairung personnel files, preparing miscellaneous recurring reports, and
receiving and distributing' mail.
.
Wortd~d
Detaill
lilme Measure
-~
.6 .,.'
Time
M8asu~ ~
Classl.tI~on
Support·OT
Activity
-',
Ongoing ActMtles
Time Per
M=Measurre
M
Provide administrative suPpo.rt for
employees
I
rrotal Hours
I
iTobI!. OT Positions IR equested (1800 Hours/Position)
Page 9 of 19
Occurrence
Occurrences
Per Year
Total Hours
1800
1800
1.0
BCP No.6
LEGAL DEPARTMENT
1.0 Tax Counsel III (Legal Counsel) - Tax and Fee Programs Division
The Tax Counsel III (Specialist) within the Tax and Fee Programs Division, Business Taxes
Section, will draft and assist in the preparation of new business taxes regulations or
amendments to existing regulations. This individual will research and render the more complex
oral and written legal advice to taxpayers and their representatives, other governmental
agencies, the Board, and its staff concerning business tax matters. The individual appears
before the Board to orally present the staffs position with respect to Board hearings on the more
complex business taxes petitions for redetermination and claims for refund. With respect to
these Board hearings, this individual researches and writes Board hearing briefs as well as
reviews complex audits, including audit work papers and related materials. Other duties include
drafting and assisting in drafting business taxes legislation as ~ell as preparing or assisting in
the preparation of various Board publications. This individual works closely and under the
general guidance of the Assistant Chief Counsel, lax CoiJnsei IV, and Supervising Tax
Counsel.
Activity
I
Cases
Hounll
I
fYearl,y )
C:as.
Draft and revise regulations, draft and revise issue and discussion pap«!rs;'
review and respond to submissions, prepare rufemaking document'S for
,
submission to the Office of Administrative Law
I
Prepare for, attend, and represent Department at Business Taxes Committee,
Interested Parties Meetings, Public Hearings, Board hearings; meetings with
staff; assist Department staff and Regulation Coordinator
Research and analyze statutes, regulations. and case laW; draft written legal
opinions
Appear before the Board in Board hearings: research and draft -SOar9ibearing
briefs
Respond to inquiries from the public and staff; assist staff in
preparation/revision of publications: draft legislation
1.0
Total legal hours
~f.~
Total legal positions requested
(\,800 hrs
pe~position)
. .1
Total
HI'S
20
400
20
10
200
20
30
500
10
40
400
15
300
20
'.'
:i
...
.20
1,900
1.1
<
\,.
.
..
1.0 Staff Services AnalY$t - LltJgatl~n DIvIsion
Under the general direction of the Supervisi/')Q' Tax Counsel III (STC III), the SSA within the
litigation Dj,vi;sion analyzes, e,va,!uates and reviews subpoena requests prepared by BOE
divisions ah· departm~nts to coorciinate processing for BOE action.
The SSA also reviews, amHyzes and evaluates tax program and employment subpoenas to
determine '(Ib~ther the $ubP..O:ena meets all statutory notice requirements and if the requested
records can be released und¢r 31pplicable law, and if applicable obtains and organizes the
records from relevant departments.
The incumbent prepares correspondence transmitting subpoenaed records or advising why
records cannot be released.
Tlme Measure
Activity
Ongoing ActMtJes
Hoursl
Occurrence
Occurrences per
Year
Total Hours
Process subpoenas, summons, and complaints for all cases
32
52
1664
Prepare monthly and summary case reports
20
12
240
1904
Total legal hours
1.0
Total legal positions requested (1800 hours per position)
Page 10 of 19
BCP No.6
A temporary position was originally created at the request of the Sales and Use Tax Department
(SUTD) to handle an expected significant increase in outgoing subpoenas used to obtain
documents from taxpayers and out-of-state retailers that had failed to comply with requests for
information. Given the adoption of AB 155, outgoing subpoenas, including subpoenas served
on out-of-state retailers with minimum contacts and nexus in California, can be expected to
continue to increase beyond the term of the current temporary position.
Therefore, this
resource is being requested to address the ongoing workload of the Litigation Division
subpoena unit which is expected to continue to experience substantial increases as a result of
the implementation of AB 155, and the related increased number of SUTD enforcement actions.
1.0 Tax Counsel III (Legal Counsel) - Litigation Division
During FY 2013/2014, with facial challenge and as-applied lawsuits against AB 155 and the
implementing regulation commencing, along with lawsuits chaHenging the application of the
retailer statute, and audit cases, the Tax Counsel (TC) III will be required to assist the TC IVs
with pleadings, discovery, legal research, motion preparation;-witness preparation, and related
litigation tasks. The TC III will be required to supplement ,the other.~ix Litigation Division
attorneys available to work on general tax refund litigati,9f{'
- --:::::---Time Measure
Ongoing '~~vities
-'
Activity
Research and analyze statutes, rules , and appellate decisions for
application to assigned cases
Prepare and present documents and briefs with courts forbearings and
trials related to assigned cases
Interview, prepare, and coordinate testimony and statements froi'll
various public and ()rivate parties related to assigned cases:' ,
Total legal hours
--
Hours/ Occurrence
100
Occurrences per
Year
11
5()
11
550
30
11
330
--
--
Total legal pOSitions requested (1800 hours per position)
Total Hours
1,100
1,980
1_1
Under the direction of·tQe Supeivi§,ing Tax Counsel III (STC III), this position will be assigned
less complex court IHigaupn cases 'involving all program areas within the Board. The position
holder will prepare/review all court filings, pleadfngs, briefs, discovery issues and other
documents nee<;ted to litigate 8s:signed cases. Other duties typically include helping to develop
litigation strategy;·· d1swyery pians and witness preparation. The incumbent will work closely
with the .? TC III, the TC:rv\the Assi~ant Chief Counsel, Deputy Attorneys General and Attorney
General staff, and in this sit-uation, the Chief Counsel.
Page 11 of 19
BCP No.6
0.5 Tax Counsel III (Legal Counsel) - Appeals Division
The Tax Counsel III (TC III) in the Business Taxes Section of the Appeals Division will decide
difficult and complex cases involving the legislation. The TC III will hold appeals conferences
and independently analyze and apply legal prinCipals to issue decisions and recommendations .
TC III position will permit the appeals associated with the legislation to be effectively and
efficiently processed in a timely manner without delay.
Activity
Cases
(Yearly)
20
Hours! Case
Total Hours
10
200
Travel
20
.5
10
Conferences
20
1
20
Post-conference gathering
20
5
100
Research and writing
20
20
7
'4
7
20
File review and preparation
Board Hearings
"
Post Decision
I
-
28
.,
140
I
Post Board Hearing
1
2
400
.,
2
1
Total legal hours
900
Total'egal position requested (1800 hours pet position)
0,5
0.5 Tax Counsel III, (Legal Counsel) - SettJement ali1d Ta,xpaye,r Services !Division
The Tax Counsel III (TC III) in the Settlement and Taxpayer Services Dlvisionl, will evaluate,
negotiate and settle cases arising out of Department bililngs related to the AB 155 legislation. A
TC III ,evaluates settlemef)t proposals and determines the risks and costs of further
administrative Ir eview and litigation i{ll,ight of the strengths and weaknesses of the Department
and the tax or fee payers factual and/or [legal arguments. The determined risks and costs of
litigation are the basis for settlement negotiations Conducted by the TC III with the tax or fee
payer. The Te IIllholds settlement comerences and prepares the settlement agreement and
ExecuHve and Attorney Genera~ Memorandums supporting each settlement. A TC III
Settleme.nt Officer pr,ir:na(i!y work~ QClleglal lissue cases but must also understand audit
procedures and techniques. The TC 11.1 Settlement Officer may also be required to attend
closed-~ssion Board meetings, atten~l meetings With executive management, and assist legal
and audit staff.
"
Aetfvtty
Evaluate Settlement P(QP9sals! review Appeals' case files, negotiate
settlements and prepare Executive and Attorney General
Memorandums. Sales & USe Tax cases=95%
Assist Legal and Audit S~
Attend Board and Executive Management meetings
Cases
(Yearly))
10
Hoursl
Case
80
Total
Hours
800
10
3
30
10
7
70
Total legal hours
900
Total \egal positions requested (1,800 hrs per position)
0 ,5
Page 12 of 19
BCP No.6
EXTERNAL AFFAIRS DEPARTMENT
Taxpayer Information Section (TIS):
As a result of this legislation the TI S estimates an additional 148,000 calls annually for the first
two years and 74,000 ongoing calls for each year thereafter. In order to handle the increase in
call volumes the TIS is requesting: 12 Tax Technician lis (6 Limited Term and 6 Permanent): 2
Tax Technician Ill's (1 Limited Term and 1 Permanent); I Supervising Tax Technician III
(Permanent); and, 1 Business Taxes Representative (Permanent). The Tax Technicians will
provide: answers to general questions; guidance to BOE resources; and, refer callers to the
appropriate sections. The Tax Technician Ills respond to the more difficult inquiries, and act in a
lead capacity by providing guidance to the lower level technicians.
The Supervising Tax Technician III is a working supervisor that plans, orglanizes, directs and
reviews the work of Tax Technician Is, lis, and 111I1s. The BUsiness Taxes Representative
provides: training to new tax technicians; reviews wolik. proces'sed by tax technicians to ensure
the work complies with the appropriate sales and use tax laws. rules and .guidelines provided by
the BOE; handles the more complex questions concerning e-fil'e servi~s or other account
specific questions; and, prepares written response to correspondence received bye-mail or
other means.
.
The tables below provide the estimated workloads for these positions, the tables represent the
first two years. After the first two years the call volume i~ ' estimated to reduce to 74.000 calls
annually and the limited term positions will have ended.
12.0 Tax Technicians 111(11 H)- 6 Perma,n ent, FIT andl '6 Umited Term FfT
Wor.idoad Detail
,I
Tlm. ,Mea$1!J1'EI
M. Mlnute
Classification
Tax Technician II
-_.
Answer ta~yer and pub,IKllnquiries
recetved on tfM! BOE, tol/ free 800 phone
number COri~mintJ the newllrogram and
the application of tax,
_
PJocess account maintenance requests.
.
"
- - .. --
-"'8.9 M
Occurrences
Per Year
OngoIng
Activities
Total Hours
148,000
21,820
300
60
,
12 M
-"
TotarJ~Technician"
"
,
' !:f '" Mours
Activity
/
"
HO!Jrs
21,860
12,0
Total TTn~c:I$~ns NeeHedI'(1,8oo
Hours/Position)' ,Cc_
"
,
- ,
2.0 Tax TecJmicians
III (TT;IU) -1 P-e rmanent, FIT and 1 Limited Term FIT
... ,.
"
Workload Detail
Time Measure
..
Classification
Tax Technician 111
Activity
Assist TaxTecnnicians with the more
difficult taxpayer and public inquiries
received on the BOE tol/ free 800 phone
number concerning the new program and
the application of tax,
Answer taxpayer and public inquirieS
received on the BOE toll free 800 phone
number concerning the new program and
the application of tax.
Assign Tax Area Codes for Business
Address Changes.
Total Tax Technician III Hours
Ongoing
Actlvltles
Total Hours
M "" Minute
H· Hours
11 ,6 M
Occurrences
Per Year
14,800
2,860
9,1 M
5.000
760
15M
200
50
Total TT III Positions Needed (1,800
Hours/Position) , _
Page 13 of 19
3,670
2_0
BCP No.6
1.0 Supervising Tax Technician III (SIT III)
Workload Detail
Time Measure
Supervising Tax
Technician III
M -= Minute
H = Hours
H
Activity
Class Iflcatlon
Supervise
Occurrences
Per Year
Ongoing
ActJvlUes
Total Hours
1,800
1.800
Total Tax Supervising Technician III
Hours
Total STT III Positions Needed (1,800
Hours/Position)
1.0
1.0 Business Taxes Representative (BTR)
Workload Detail
Time Measure
Classification
Business Taxes
Representative
M -= Minute
H = Hours
ActJvlty
Provide training to current and new Tax
Technicians.
Develop. revise and update training
materials.
Answer Taxpayer Inquiries received by
Internet email.
Monitor and evaluate Tax Technicians for
accuracy and effectiveness.
Tolal Business Taxes Representative
Hours
Tolal STR Positions Needed (1,800
Hours/Position)
Occurrences
Per Year
Ongoing
'. Activities
Total Hours
t:I
870'
H· .
150
H
480
H
300
1,800
1.0
4.0 Business Taxes Specialists
In order to ensure the most effective implementation of AB 155 or possible federal legislation,
the BOlE Outreach 'SeN,ices Di\iis10n will need to develop in a comprehensive statewide
outreach and educati.on prOgram io address comp'ilance by both business and consumers, and
to clarify any cQnfusion a:bo~ sales and use tax'responsibility. The Business Taxes SeNices
SpeCialists win be loCated at our field offices and will facilitate this ongoing statewide outreach
directly to ta,xpayers4>ractitioners as well as participate in partnership activities with
stakeholders, community .organizations, and local, state, federal government agencies in an
assigned geographical are . Outreach activities will include conducting workshops, seminars,
and attending or participating ilf custo'mer assoclation conferences and meetings.
The tables below provide the estimated workloads for these positions:
Page 14 of 19
BCP No.6
4.0 Business Taxes Specialist I (BTS I)
Workload Detail
Time Measure
Business Taxes
Specialist I
Occurrences
Per Year
M = Measure
H '" Hours
H
Activity
ClasslRcatlon
Outreach Annual Work Plan
External Stakeholders Database
Development
Survey Creation, Compilation, Analysis.
Ongoing
Activities
Total Hours
320
H
880
H
120
H
2,400
H
-',3,744
R~ort
Stakeholder Meeting and Event
Participation
Pre--workshop planning (logistics,
Ipublicity)
Conducting Workshops
Total Business Taxes Specialist I Hours
H
~r
520
8,080
4.0
Total BTS I Positions Needed
1(1,800 Hours/Position)
1.0 Audio Visual Specialist, Outreach Services Division
As a result of this legislation, the BOE Outreach Services Division, Online and Media Services
Section, will need to address the educational needs of taxpayers who are unable to attend live
meetings, conferences, and seminars. The Audio Visual Specialist will do so by creating
outreach tools for both businesses and consumers including public service announcements,
online videos, and webinars. This type of outreach is a valuable compliance tool that presents
an opportunity to educate and interact with large numbers of taxpayers at once and is also an
effective preventati,ve and remedial: tool (or systemic and regional noncOmpliance.
Workload Detail
Time Measure
I
M'l!" Measure
ClassLflC<ltJOIlJ
Audio Visual
Specialist
-
Public' Service Announcements
Video WorkshopS
,
.
Weblnars
~
c
r:--
-
I Occurrences
Per Year
Ii '" Hours
Activity
Total Auelia VISual Speclaljst 'Hours
Total AVS Positions Needed
.(1,800 HoursJPosItion)
--
Ongoing
Activities
Total Hours
'H
320
-H
1,280
320
H
I
1,924
1,0
EXECUTIVE DEPARTMENT
Legislla.tive Division
Due to the complexity, poHtrcal sensitivity, potential litigation, and associated high volume of
workload associated with A8x1 28 and 155, the Legislative and Research Division has identified
the need of additional resources: 2.0 Business Tax Specialist (BTS) III positions. The
increased workload requires the highest degree of analytical expertise, and involves drafting
complex technical language, testifying before the Legislature, meeting and advising legislators
and their staff, other state officials, and Board Members and their staff of the new law relating to
nexus in California effective September 15, 2012 or January 1, 2013, and the alternative
approach as outlined in AB 155, which contemplates federal legislation and conforming state
legislation that is enacted on or before September 14, 2012, and to effectively perform these
tasks.
With respect to the alternative federal legislation, it is assumed at this time that the Streamlined
Sales Tax Act, will initially be explored as the solution. However, other ideas will be explored,
Page 15 of 19
BCP No.6
as well. The California State Board of Equalization, which administers the sales and use tax for
State and local jurisdictions, will be the lead agency that the Legislature, the Administration, and
other States wilt look to for leadership on both the nexus and the Streamlined Sales Tax issues.
2.0 Business Taxes Specialist III (1.0 Permanent, 1.0 2-year Limited-Term)
Time
Measure
Classification
Activity
BTS III
Providing technical expertise to the
Legislature. Administration. Board Members
and staff. and outside agencies,
TeChnical drafting of complex and sensHive
statutol)llanguage and correspondence on
nerus and Streamlined Sales TaJ( issues.
Preparing BOE staff legislative analysIs of
complex and sensitive legisia1lve business
taxes bills. Includmg nexus. and the
Streamlined Sales Tax Project and
coordinating the cost and revenue estimates
for the analyses.
T&Slifying before the Legislature and WE.
Total Hours
Total Posrtion(s) Requested
OngoIng Activities
nme Per
Occurrence
varied
Occurrences
Per Year
Total Hours
H'" Houni
H
varied
1,800
H
varied
varied
800
800
H
varied
varied
200
3,600
'-.
Page 160f19
2.0
BCP No.6
OF·d-o (REV Q!J/< '.1
FIscal Summary
(DoNafs If, /housar;dsl
8CP No.
Program
30 Sales and Use Tax
IProposal Title
AS 155
G
Perronal Services
PosItions
BY·1
BY
28.3
--1.3
27.0
Total Salaries and WaQes
Salary SavinQs
Net Total Salaries and Wa~es
Total Staff Benefits ~
Salary Sa-Jings
Net Total Staff Benefit!'.
Distributed Administration
Total Personal SeNiee$.
BY·2
307
.. 1 5
292
270
·1
Dollars
35 1
--1.7
33.4
29.2
33.4
o'peroling Expenses and E:qulpment
General Expense
Distributed Administration
Prinling
Communications
BY
BY·1
8Y+2
51.948
51477
-570
S1407
5537
-527
5510
S1717
S1.917
52.229
$2.529
$340
598
$137
5137
535
S44
5182
5122
526
85
5198
5122
529
5380
S5
5198
5196
533
5376
56
570
S50
575
527
S85
529
$1.264
S969
51.1 0.:1
53,180
53.197
53.633
-S81
51 636
$624
-531
S593
-592
51.856
S70S
-535
5673
Posta~e
TrB'/el-ln State
Tra'/el-Out of State
Trainin!:)
Facilities Operations
Utilities
ConsultinQ & Professional Services
Consulting & Professional Services
Data Center Sel',ices
Information Technolo~y
Equipment!
OtherlSpecial Items of Expense. 4
Total
OpBreltin~
5332
Inter::le~artmenlal '
Exter~al
'
Expenses and Equipment
Total State Operations Expenditures
Fund Source
Org
General Fund
0860
Special Funds'
Federal Funds
Other Funds (Speciti)
REI imbu rsem ents
0860
Total Local Assistance Expenditures
Fund Source
Item Number
Ref
Fund
001
0001
52 083
S2.094
$2.380
001
0995
$1.097
S1.103
S 1.253
$3.180
S3.197
$3.633
11em Number
Org
Ref
Fund
General Fund
Special Funds~
Federal Funds
Other Funds (Specify}
Reimbursements
Grand Total, State Operations and Local Assistance
• Hemlze ~csrtlons I:y clau"fjC;!ltlon en th~ Perscn81 Ser,ICe-3 Oetail wcrtsheel
; ?rc',kle benefit delnil en Ihe PerscnIIl SerYlcell Delli II .... oro:Sh~t.
I
f'ro·.. .:Ie hst on the SU?pll!,~~t81 tnlcrlmtion \'lor1cshe-e1.
j
Other;Speclal Hems of EXIl~n$e must ~ IIslea inOkldual~'. Refer to the Umform Co.:le! t.18~u81 fer 8 Ii!I 01 !t~n~er~ We!.
, Attach 8 Fund Cond~lGn Sistern&nt that ref1e.cb special flJn~ or tond fund el<~enoiture! (cr re·,enue) 8! prc~o!e:l
Page 17 of 19
BCP No.6
Personal Services Detail
(Whole dollars)
BCP No.
IProposal Title
AB 155
G
S8 I anes
8n dW uges
Classification
De Uu'1
Sahory
PosltJo .....
~
DolI.H!I
R&no<>
BY
SUTD
Data Analvsis Section
Business Taxes Spe-cialist III af
Business Taxes Specialist II b/
Out·Of·State
Business Taxes Specialist I cl
Associate Tax Auditor c./
Office- Te-chn'cian cl
LEGAL
1.0
0.8
BY..·1
BY----2
1.0
1.0
BY-+1
BY
1.0
1.0
$87.708
$76.116
S87.708
S60.893
2.0
2.0
1.0
$70.824$63.096
$35.700
BY+2
S87.708
$76.116
S87.708
$76.116
SO
SO
$0
SO
SO
$0
$141.648
$126.192
$35.700
Tax.anclEee
Tax Counsel III (Spe<:ialistj a/
litioalion
Staff' Services AnaJyst a/
Tax Counsel III (Specialist) dl
Aooeals
Tax Counsel III '-Specialist) dl
Settlement and Taxoaver Svs dl
Tax Counsel III (Specialist)
EXTERNAL AFFAIRS
Customer SelVice & Publishina
Tax Technician III el
Tax Technician II (I
Supervising Tax Technician III aJ
Business Taxes Representative al
Outreach ~!'ii.c.e:s
Business Taxes Specialist I aJ
Audio Visual Specialist al
1.0
1.0
1.0
5102,960
5102.960
$102,960
S102.960
1.0
1.0
1.0
1.0
1.0
M3.584
$102.960
S43.584
$0
:&43.584
S102.960
S43.584
S102.960
0.5
0.5
$102.960
SO
551.480
$51.480
0.5
0.5
1102.960
$0
$51.480
551.480
2.0
12.0
10
1.0
2.0
12.0
1.0
1.0
2.0
12.0
1.0
1.0
$39.240
$35.088
$78.480
5421.056
$78,460
$.421.056
$78.480
5421.056
$4.4.664-
$4.4,664-
$44.664-
$44-.664-
$46.656
$46.656
$46.656
$-4.6.656
4.0
1.0
4.0
1.0
4.0
1.0
$70,B24
$58.488
$283.296
$58.488
5283.296
$58.488
$283.296
$58.488
2.0
2.0
1.0
$87.708
$175.416
$175.416
S87.708
0.1
1.5
0.0
1.7
2.1
2.1
0
73.562
0
92.272
107.676
28.3
30.7
35.1
$1.476.763
$1.116.616
$1,947.652
EXECUTIVE
BUSiness Taxes SpeCialist III
g/
Blanket Funds.
Overtime
Temporary Help
Total Selarlos end Weges )
Staff Ber>4!lflts Detail
OASOI
HealthlDentalNision Insurance
Retirement
Miscellaneous
Workers' Compensation
Industrial Disability Leave
Non-Industrial Disability Leaw
Unemplovment Insurance
Other:
254,597
1.270
1.137
739
4,%3
$536.610
1.030
1.477
1.322
8S9
5.769
$623.804
1.169
1.675
1.500
974
6.545
$707.727
52.013.373
$2.340.4.20
$2.655.579
aB6
TOlel Slllff Benef1ts ~
BY
+ 1
149,022
257.993
288.849
CY
112.991
195.614
219.010
Grand Totel, Personol Services
BY
0
131.351
227.399
, Use slandard alltlreviations per the Salaries and Wages Supplement Show any e1Tec\iYe date or IImlled-term expiration dale in
parenttleses it the position is not proposed for a full )lear or is not permanent. &.0 (&XP 6-30-13) or (err 1-1-13)
Note: Infonnallon prOYlded should appear In the !UlIma 10rmat liS It woUd on the Changes In Authorl:ted Po-sltiornl.
'If mulUpla proorams reQUire pOsitions. please InClude a 5utlneadlno under the classtflcaUon section 10 Identlt)· pOsitions by
l Tolals must be rounded to the neareslthousand dollars berore posting 10 the Fiscal Summary.
_aJ Permanent postuon eITectlve 71112012.
_01 Permanent pOSition errec:\ille 91112012
_cJ Permanent pOSition efrecUlIEi 71112014.
_dJ Permanent position effective 71112013.
_01 lOot the 2.0 pOSitions is a 3-yr Ilmitee! term position to e~p ire 06130115 The other 1.0 positi on is perman anl
_116.0 ofltia 12.0 poslbons Is a 3-yr limited term position 10 expire 06130115. The other 6.0 posl~ons are permanent
oJ 1 0 or the 2.0 posi~ons Is a 2-vr limited lerm posltlon to eXPire 06130114 The other 1 0 posl~on 19 Dermanenl
Page 18of19
BCP No.6
Suppiementallnformation
(Dollars in thousands)
IProposal Title
BCP No.
AS 155
6
Equipment
BY
Standard Complement
Total
BY+2
BY+1
$794
$560
$665
$794
$560
$665
C onsu It·mg & P rof ess ona IS erv ces
Total
Facility/Capital Costs
Attorney Office
Total
G
No
One-Time/Limited-Term Costs Yes
Description
BY
Positions
Dollars
$340
$108
$32
$25
General Expense
Communications
IT
Facilities
0.0
Full-Year Cost Adjustment
D
BY +1
Positions
Dollars
$25
$2
$3
$50
0.0
$505
Yes
G
No
580
00
Future Savings
Yes
D
No
$62
$5
$4
0.0
$71
D
Provide the incremental change in dollars and positions by fiscal yea,BY +1
Item Number
BY
Positions
Dollars
Positions
Dollars
Total
BY +2
Positions
Dollars
BY +2
Positions
Dollars
2.4
$17
4.4
$436
2.4
$17
4.4
$436
D
Specffy fiscal year and estimated savings including any decrease in positions.
BY +1
Item Number
BY
BY +2
Positions
Dollars
Positions
Dollars
Positions
Dollars
I
Total
0.0
0.0
Page 19 of 19
0.0
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