minds of people. You come in here and say that you are not going to notify individuals because it would cost $200,000. How many hundreds of thousands of dollars did it cost to maintain this illegal system? Nobody ever discussed that. But you used the taxpayers' dollars to maintain an illegal system and to spy on us. You did not worry about the cost-effectiveness then.

How can you then come in here and say, "Oh, no; we cannot notify these people because it is not cost-effective. It is going to cost $200,000. Two hundred thousand dollars-if it is true-is a small price to pay for the restoration of confidence in the Internal Revenue Service. It is a small price to pay considering the cost to our precious democracy, not only in dollars, but the cost of invading the privacy of individuals the cost of violating both laws and the Constitution. That is a big cost. And it is not for you to say now that it may cost a few dollars. It is not for you to decide that it is not cost-effective.

Mr. ALEXANDER. You have posed a number of questions. First, I wish someone had focused on cost-effectiveness when they set up this Special Service Staff. Maybe it never would have been set up.

Second, I am glad that the Special Service Staff did not result in massive assessments against those on the list or the targets of the Staff. Had it operated more effectively, I think it would have been more of a problem to the tax system and to the people.

Ms. ABZUG. May I interrupt you at this point? Having been a victim of one of your operations, I say that the reason that it did not result in more moneys is that we are law-abiding citizens. I got a refund after one of your audits. The people you were investigating were lawabiding citizens and not even the distortions of those units could change that.

Mr. ALEXANDER. I am fully aware that you were on the "enemies list."

Ms. ABZUG. And that is so of a good number of people who were investigated because they were on political lists and so on. We know that situation.

Mr. ALEXANDER. I am aware that you were on the "enemies list," Ms. Abzug. I hope that actions the Internal Revenue Service has taken in the last 3 years, including one taken quite recently, will prevent the possibility of any future "enemies list" or a misue of the Service, such as those described in the Church report and in other reports and as has been done a number of times in the past-the recent past and otherwise.

Ms. ABZUG. In May of 1973, the IRS established the Information Gathering and Retrieval System. The IGRS was a new approach to intelligence gathering and to the storage and retrieval of so-called general intelligence, as contrasted with intelligence developed in the course of investigation of a specific tax case. What action has been taken recently with respect to the IGRS?

Mr. ALEXANDER. As far as intelligence gathering is concerned, we have put a hold

Ms. ABZUG. I withdraw that question. I want to continue with this. What about the information that was put in the IGRS? Will that all be destroyed under your plans or under your projected plans?

Mr. ALEXANDER. I am only talking about the Special Service Staff files. We would like to get rid of the Special Service Staff files.

Ms. ABZUG. Wasn't the Special Service Staff information put into the IGRS?

Mr. ALEXANDER. No; I don't think so. Was it, Mr. Kuehling?

Mr. KUEHLING. It had no connection.

Ms. ABZUG. It had no connection. So not everything is in this IGRS. In other words, this is not a total storage and retrieval of so-called intelligence?

Mr. ALEXANDER. NO.

Ms. ABZUG. You have other stuff that you keep in other indices. Is that right?

Mr. ALEXANDER. The Special Service Staff files were quite separate and still are quite separate because we are holding them pending the completion of congressional inquiries such as yours. We intend to continue to hold them until your inquiries are completed.

MS. ABZUG. Did you put the names in that IGRS?

Mr. ALEXANDER. No.

Mr. KUEHLING. We did not. To my knowledge, there is no connection between the two.

MS. ABZUG. What are you doing with the IGRS file?

Mr. ALEXANDER. The IGRS is simply a computer system for storing information that we gathered with respect to people about whom it was logical to have concern. The problem with the system was that it grew like Topsy and that it was not properly supervised. We put a stop to that system. Since then we have issued new and much more more restrictive information gathering guidelines. And at least one congressional committee is concerned about whether we are too restrictive.

Ms. ABZUG. Are you not concerned about that information which is improper which is in there? How are you going to get at it? There is a lot of improper information in the IGRS. Will you grant me that?

Mr. ALEXANDER. These are names. And they are somewhat silly names because one of them is the Internal Revenue Service. And I think we would have considerable concern about why we want to list the Internal Revenue Service as a taxpayer or a nontaxpayer, as the case may be. There are names of former Commissioners. My name is in IGRS.

The IGRS system was probably a good idea at the time for computerizing and developing a system which would be better than what it replaced, which was a by-hand oxcart type of system. The problem was that too much was placed in it with too little management attention. And so we put a stop to that.

MS. ABZUG. How many subjects are in the IGRS file?

Mr. ALEXANDER. As I stated, I think that a check of 21 districts showed something like 465,440 names in the old IGRS system. Ms. ABZUG. Is that 21 out of 50 districts?

Mr. ALEXANDER. I think that was a check of 21.

Ms. ABZUG. But if there are 50 districts, it is conceivable that you could have over a million names, isn't it?

Mr. ALEXANDER. I think that is highly improbable. I think the ones we included are big districts. Manhattan would have a lot more names than Cheyenne, Wyo., for example.

MS. ABZUG. It is nice to know that. We get a lot of big things, but not commensurate with what we are entitled to get.

Mr. ALEXANDER. I should have used Los Angeles. Right after I said "Manhattan," I knew I had said the wrong thing.

Ms. ABZUG. What is going to happen with the IGRS under your purging system?

Mr. ALEXANDER. I don't know. I am going to find out about IGRS this morning—or this afternoon, as the case may be--and see what on Earth we have done after we called a halt to it.

Ms. ABZUG. I think it is interesting. We may have to revise our bill to include the IGRS.

Mr. ALEXANDER. I hope that if you do, you will increase the Internal Revenue's budget to take care of the problem of cost.

MS. ABZUG. Let us not worry about that. You didn't worry about it. You expended all kinds of taxpayer's dollars. We will take care of that properly.

When someone writes the IRS under the Freedom of Information Act, do you inform him that his name is in the SSS file or the IGRS, if that is the case?

Mr. ALEXANDER. Mr. Keightley, will you answer that?

Mr. KEIGHTLEY. In cases where anyone indicates either an interest or feeling that he was on the SSS list, the Service

Ms. ABZUG. But he or she has to know if he is on the list. Is that right?

Mr. KEIGHTLEY. That is not what I said.

MS. ABZUG. Then let's get that very clear.

Mr. KEIGHTLEY. What I said was that if he asks if he is on the list or indicates some interest in unnamed lists, without knowing the type of list, we will, if we have an indication that he is interested in it, search the lists to determine if the name is on the list and process the request under the Freedom of Information Act.

Ms. ABZUG. If I write to you and say, "I understand you have a file on me," what do you then write to me?

Mr. KEIGHTLEY. We would ask you in what connection. We need the clarification because it may be an audit and you may be on a district file in Los Angeles or wherever. You may just want to know about that file. So we would usually ask for clarification.

Ms. ABZUG. So even if I ask for the information, you don't give it to me. Right?

Mr. KEIGHTLEY. When you ask for the information, we give it to you. Ms. ABZUG. But I have to know what secret files you have on me. Right?

Mr. KEIGHTLEY. You do not have to know what secret files.

Ms. ABZUG. You just said that.

Mr. ALEXANDER. I do not think he did, Madam Chairwoman.

Ms. ABZUG. You tell me again what happens. If I write to you and ask if you have a file on me, then you write back and say: "What kind of file are you talking about?" Is that right?

Mr. KEIGHTLEY. Specifically, we have a decentralized

Ms. ABZUG. Isn't that right?

Mr. KEIGHTLEY. Yes.

Ms. ABZUG. You don't take a quick look and say, "We have it in SSS or another file," and then notify me of that?

I am really trying to get this process in my head for the benefit of your procedure and our procedure. And I want to make sure that the

Privacy Act and the Freedom of Information Act are being carried

out.

Mr. KEIGHTLEY. That is what I am trying to describe.

Ms. ABZUG. Now if I write to you and if I ask you if you have a file on me, you would then write back and say, "What kind of file are you talking about?" What do you write back?

Mr. KEIGHTLEY. We attempt to

Ms. ABZUG. While I remember, I would like you to provide for the committee, without names, necessarily, because I do not want to invade anybody's privacy, 10 such requests in the last period of time. We would like the questions and the answers, but without the names so that nobody's privacy is invaded.

Let the record show that we have requested that.

[The material requested is contained in the subcommittee's files.] Ms. ABZUG. Now, tell me the procedure.

Mr. KEIGHTLEY. The procedure is to attempt to provide people realistic help under the Freedom of Information Act and the Privacy Act. If we get a request and somebody says, "I want the file which IRS has on me," we are at a loss as to know where to look. Should we look in 52 districts; should we look in Service centers; should we look in the Intelligence Division-where should we look?

It certainly would not be cost productive for every request of that nature to result in a search of every possible district. So in an effort to provide them with what they are entitled to under the Freedom of Information Act or the Privacy Act, we contact them and say, "Could you be specific? Could you tell us the area where you live? Could you give us a hint as to what you are looking for?"

Usually the people will be able to tell us what they want. But, I think we have an obligation to do that under the Freedom of Information Act and the Privacy Act and not to spend a fortune looking for something that may not exist.

MS. ABZUG. Don't you have an index?

Mr. KEIGHTLEY. We have many indexes. That is one of the problems.
MS. ABZUG. How many indexes do you have?

Mr. KEIGHTLEY. I would not begin to know.
Mr. ALEXANDER. Do you know, Mr. Gibb?

Mr. GIBB. I have no idea.

Ms. ABZUG. How many systems do you have?

Mr. KEIGHTLEY. I don't know the total number, but we have a book covering all of the systems of records.

Ms. ABZUG. Ask one of your colleagues there.

Mr. KEIGHTLEY. I am advised by Mr. Gibb that it is in the neighborhood of 300.

Ms. ABZUG. How many master indexes do you have?

Mr. KEIGHTLEY. I do not know what you mean by master indexes. Those are the systems of records under the Privacy Act.

Ms. ABZUG. Do you have any index systems?

Mr. KEIGHTLEY. I have already said that we do have indexes.

Ms. ABZUG. How many do you have?

Mr. ALEXANDER. But we do not have one index for all of these systems.

Mr. KEIGHTLEY. You can't push a button in the Service to obtain everything we have on an individual. We regularly deal with the prob

lem of people saying, "Why can't you just push a button and give me everything you have on me?" We don't have such a capacity. I have difficulty finding out where things are and I work there.

Ms. ABZUG. How long have you worked there?

Mr. KEIGHTLEY. About 10 years.

Ms. ABZUG. You should know by now where things are.

Since you have been working there for 10 years and have had an occasion to deal with the indexes and you are in charge of Privacy, how many indexes would you say there are?

Mr. KEIGHTLEY. The only survey that was done was done for the Privacy Act. There is a list of systems and records in the Privacy Act. The approximation is 300.

Ms. ABZUG. And what kind of indexes do you have?

Mr. KEIGHTLEY. I don't see how you distinguish between an index and a system of records. A system of records is material that is retrievable in identifiable form on an individual.

Ms. ABZUG. You see, it strains credulity. You have set up an IGRS system and put everything in this little computer. A lot of other agencies have done it and we have master indexes to them. But somehow or other, when we get into the question of how many indexes there are, nobody knows.

Do you know?

Mr. GIBB. No. I would assume there is something akin to an index reach of the system.

MS. ABZUG. I would assume that.

Mr. GIBB. They are systems that are retrievable by name or number. Therefore, there is some kind of an index or some method of getting access to all of the systems.

Ms. ABZUG. And is there in this whole agency, which is collecting all of this information and dollars and so on, not an interrelated system of indexes?

Mr. ALEXANDER. Not that I know of, Madam Chairwoman. That is one of our many problems.

MS. ABZUG. What do you think?

Mr. GIBB. The only thing, to my knowledge, that would in any way might be considered a compendium of any sort would be the individual master file itself. This is a record of tax returns filed.

Mr. ALEXANDER. But that doesn't have anything else in it.

Mr. GIBB. It does not interrelate, but there would be some overlap in what might be recovered.

Ms. ABZUG. Let me get off that subject.

Supply for this committee the information of the number of systems, the number of indexes, and what interrelated master index systems there are.

[The material follows:]

The Internal Revenue Service has reported 208 Systems of Records subject to the Privacy Act of 1974.

The concept of Systems of Records did not exist in the Internal Revenue Service prior to the advent of the Privacy Act. The 208 reported systems represent the Service's attempt to report all records which are subject to the Act in terms which meet the definitions provided by the Act. Broadening the definitions provided by the Act, including records relating to an individual's entrepreneurial capacity (such as may be on our Business Master File), or attempting to respond to a request for "all records about me" would of necessity expand the Service's systems well beyond the reported 208.

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