Select Committee on Public Accounts Thirty-Third Report


The Committee of Public Accounts has agreed to the following Report:



1. The Inland Revenue introduced self assessment for income tax and capital gains tax in 1996. Self assessment applies to more than 8 million self employed and higher-rate PAYE taxpayers, 700,000 partnerships and 300,000 trusts. In 1999-00, these taxpayers paid more than £55 billion income tax, national insurance contributions, and capital gains tax, of which £40 billion was collected through PAYE and other forms of deduction at source. The self assessment project represented one of the largest changes in tax administration for decades, making assessments more straightforward with one assessment covering all income and gains.[1]

2. On the basis of a Report by the Comptroller and Auditor General,[2] we looked at how the Inland Revenue assessed the sums at risk from self assessment, how effective they are at getting tax returns in, how they use intelligence and conduct enquiries to ensure compliance and what they are doing to help taxpayers meet their obligations.

3. In the light of this examination, the Committee draws three overall conclusions.

  • There is no firm estimate of the overall hidden or non-observed economy, and there are data and methodological problems with the different models that have been used to attempt to quantify it. Until these difficulties can be overcome, there might be advantage in focusing instead on reducing the size of the unknown elements of economic activity, and gaining a greater knowledge of the risk areas. As part of this work, the Inland Revenue should estimate the sums lost or at risk in specific taxes and measure their performance in reducing them.

  • The limitations of the Inland Revenue's management and information systems continue to hamper their efforts to increase taxpayer compliance on self assessment. Better information is needed, for example on the effectiveness of sanctions to encourage prompt filing, and on why the proportion of returns submitted on time is falling.

  • To improve taxpayer compliance, and increase the revenue collected, the Inland Revenue's aim must be to devise a system and guidance that is simple and clear enough for most taxpayers to comply without the need for expensive tax advice. This reinforces the work they are doing with groups such as Citizen's Advice Bureau, the Low Income Reform Group, the Chartered Institute of Taxation and the Institute of Chartered Accountants in England and Wales to understand user needs, simplify tax systems and provide help and guidance.

4. Our more specific conclusions and recommendations are as follows.

On assessing the sums at risk

      (i)  There are difficulties in obtaining a firm estimate of the overall hidden or non-observed economy. However, as we have seen from our hearings on fraud against indirect taxes, most recently on alcohol and hydrocarbon oils, HM Customs and Excise have used innovative approaches to assess levels of fraud in particular taxes, and to develop measures and targets for tackling them. The Inland Revenue should speed up the work they are doing to assess the sums lost or at risk in specific taxes.

On getting tax returns in

      (ii)  The Inland Revenue deploy a range of initiatives and sanctions to encourage taxpayers to submit their returns on time. Yet the proportion doing so has fallen year on year. Their Taxpayer Filing Initiative should enable them to understand taxpayer behaviour better and help them develop new initiatives. They should consider the greater use of sanctions to encourage filing on time, and set a firm target for achieving compliance.

      (iii)  The Inland Revenue explored the benefits of daily penalties following recommendations by the Comptroller and Auditor General, and now intend to make greater use of such penalties. They should regularly reassess the effectiveness of each of the sanctions available: fixed penalties, determinations and daily penalties.

On using intelligence and enquiries into tax returns to ensure compliance

      (iv)  Information supplied by third parties is a valuable source of intelligence on possible non-compliance. But its use and dissemination within the Inland Revenue are still hampered by weaknesses in their Project Support System. Their review of this system should be completed quickly, so that their intelligence and enquiry staff has access to modern systems that enhance their work.

      (v)  The sums at risk from non-compliance by taxpayers in completing their self-assessment returns are substantial: an estimated £3 billion in 1996-97 returns and £1.8 billion in 1997-98. The Inland Revenue needs to complete their further research into the scale of the risk, and measure their performance in reducing this risk by well-targeted and properly researched enquiry work.

On helping taxpayers meet their obligations

      (vi)  The Inland Revenue rightly attaches importance to reducing the compliance burden on small businesses and helping people understand and comply with the self-assessment system. They are working with groups such as Citizens Advice Bureaux, the Low Income Reform Group, the Chartered Institute of Taxation and the Institute of Chartered Accountants in England and Wales to understand user needs, simplify tax systems and provide help and guidance. The Inland Revenue should assess the impact of the changes they make by seeking more direct evidence from their customers of real progress in reducing compliance costs.


5. In looking at the sums at risk in the tax system, the Inland Revenue differentiate between the tax gap and the hidden economy:

6. The Inland Revenue considers that estimating the overall tax gap would be very difficult and would require a great deal of time and effort. As regards the hidden economy, Lord Grabiner QC, in his March 2000 report on the Informal Economy,[4] concluded that while it involved billions of pounds, it would be impractical to arrive at a precise and meaningful figure without a considerable investment of time and resources. Earlier work suggested a figure of between six and eight per cent of gross domestic product.[5]

7. The Organisation for Economic Co-operation and Development (OECD) doubt the value of the various models that have been devised to quantify the hidden economy because of data and methodological problems. In their handbook for the measurement of the non-observed economy, OECD focus instead on reducing the size of the unknown elements of transactions and production, and gaining a greater knowledge of the risk areas.[6]

8. The Inland Revenue are using new powers of random enquiries to refine their indicators of risk and have intelligence and analysis teams to identify where the highest risks lie, so they can target their activities more effectively.[7] Based on this work, the Comptroller and Auditor General produced some broad estimates of the potential amounts of tax at risk from selected elements of the self assessment process (Figure 1).[8]

Figure 1: Potential tax at risk at stages of the self assessment process
Identification of taxpayersDifficult to estimate impact of hidden economy but assumed to be significant although some overlap with "conduct of enquiries" estimate.
Return managementInland Revenue estimate that between £150 million and £300 million tax may be at risk each year from returns not filed by six months after the statutory deadline.
ProcessingThe Department's quality monitoring suggests that processing errors are likely to lead to gross errors of the order of £100 million.
Conduct of inquiriesThe Department's analysis of random samples of returns for 1996-97 and 1997-98 produced different estimates of the annual potential tax at risk from non-declaration of income or gains (£3.0 billion and £1.8 billion). There will be some overlap with the hidden economy.
Debt managementFinancial records indicate that while substantial sums are not paid by the due dates, eventual write-offs have amounted to less than £0.05 billion per year to date.
AccountingAnnual audit work suggests very low risk of diversion of tax paid over to Department.
Source: National Audit Office


9. The annual tax return is the cornerstone of the self-assessment system. If taxpayers fail to file a return, the Inland Revenue cannot check whether they have paid the right amount of tax or open an inquiry into their affairs.[9] We looked in more detail at progress in getting tax returns in and the use of penalties and other sanctions to ensure submission of tax returns.

  (a) Progress in getting tax returns in

10. Following extensive advertising campaigns to encourage filing, around 90 per cent of taxpayers filed their returns by the 31 January deadline in each of the four years to 1999-2000, although the position deteriorated slightly year on year. The Inland Revenue estimated that up to around £300 million could be at risk from the 500,000 or so 1998-99 returns still outstanding by August 2000.[10]

11. The Inland Revenue told the Committee they did not know why the percentage of self-assessment returns had dropped slightly. This was one of reasons they had launched a Taxpayer Filing Initiative to try and find out which groups of taxpayers were most prone to late filing and why, and then to agree a programme of initiatives to encourage early filing and take forward longer term actions to improve performance.[11]

12. They used a range of measures to get returns in. Each year they contacted all of the taxpayers who were late in submitting their returns before the January deadline.[12] They also identified and got in touch with people whom they would have expected to have submitted a return but had not done do by 31 January, including over 350,000 people who had filed late for the last two years running. For example, using their new receivables management business stream they had sent letters to 600,000 people in March 2001 and by the end of April had received 150,000 returns and an additional £230 million in tax. They had also transferred responsibility for chasing returns to telephone pursuit units, which had succeeded in persuading 23 per cent of taxpayers contacted to send in completed returns. In addition, the Inland Revenue were having a blitz on long outstanding returns, and had a target of clearing 40 per cent by 2002. In these ways, they hoped to push compliance by 31 January each year up to about 94 or 95 per cent.[13]

(b) Sanctions used to encourage the filing of tax returns

13. The Inland Revenue also use various sanctions to encourage the remaining 10 per cent of taxpayers to file their returns on time. They levy an automatic fixed penalty of £100 if a return is late. A further £100 penalty is charged if a return is more than six months late. If the return is more than a year late, the taxpayer may be charged a penalty of up to 100 per cent of the tax due on the return, in addition to having to pay the tax itself. Between February 1998 and August 2000, the Inland Revenue issued 4.9 million fixed penalty notices. However, the Comptroller and Auditor General found that in 23 per cent of cases (1.1 million) the fixed penalty related to taxpayers with residual liabilities below £100 and was reduced to the level of the tax outstanding, thereby reducing the incentive for taxpayers to file their returns.[14]

14. The Inland Revenue explained that in cases where the tax was below £100 the penalty was capped at the level of liability but was levied in addition to the tax. Thus, if the tax liability was less than £100, say £99, the taxpayer had to pay the tax outstanding plus a penalty of the same amount, £198 in total. In their view this was a significant sum for those who owed relatively small amounts. The Inland Revenue did not have management information on the collection of fixed automatic penalties, because they regarded them as part of the overall self assessment debt. However, in 1999-2000 they collected just under £118.5 million in fixed penalties, and they had a target to collect 72.9 per cent of outstanding debt during the year to April 2002, which they expected to either meet or slightly exceed.[15]

15. If taxpayers repeatedly did not send in their tax returns, the Inland Revenue would move to using determinations (estimates of the amount of tax to be paid) to encourage them to do so. The taxpayer has no right of appeal against a determination, and must either pay the amount demanded or submit a completed return showing why the estimated amount is incorrect. The Inland Revenue had issued 104,000 determinations since January 1998, but less than 40 per cent had led to the submission of completed returns.[16]

16. In cases where determinations did not work, and taxpayers missed two year's tax returns, the Inland Revenue would start to levy daily penalties. The Comptroller and Auditor General found that these appeared to be an effective means of encouraging taxpayers to submit completed returns. However, local tax offices were reluctant to levy daily penalties, of up to £60 per day, because of the complexity of the process involved, a reluctance to take large numbers of cases to the General Commissioners, and confusion as to when these penalties should be applied. Six of the seven local offices visited had not levied daily penalties.[17]

17. The Inland Revenue told the Committee that they had found the Comptroller and Auditor General's findings on the effectiveness of daily penalties extremely helpful. Since his Report, they had staged a trial, which had confirmed that daily penalties were very effective. It showed that when they told people they were going to use daily penalties, 80 per cent sent their returns in before the case went to the Commissioners and a further 16 per cent did so before the Commissioners heard the case. As a result, the Inland Revenue expected them to be used more often.[18]

18. The Comptroller and Auditor General found that the Inland Revenue did not routinely collect information on the use and effectiveness of the various sanctions they use to encourage late filers. They had only recently begun to look into taxpayer behaviour to establish the reasons why returns are not filed on time. The Inland Revenue accepted that they needed to do more to assess the effectiveness of the different measures they used, and to improve their management information systems.[19]


19. All taxpayers have a legal duty to notify the Inland Revenue of taxable income and gains and to pay any tax arising. However, some will fail to do so. The Inland Revenue have a range of systems and controls in place to identify taxpayers who should be using self assessment.

20. We looked at four areas: the effectiveness of intelligence activities, access to and use of third party information, the effectiveness of enquiries into tax records, and lessons learned from best practice overseas.

(a) The effectiveness of intelligence activities

21. Non-compliant taxpayers often operate in the "hidden" economy, which covers tax evasion of all kinds. This includes the failure of individuals to register for tax (ghosts), the non or under-declaration of casual work and cash income (moonlighting), through to organised crime. The Inland Revenue sought to identify such individuals through intelligence work. This was generally organised into projects concentrating on a particular trade or information source, and included information obtained from other public sector agencies, other sources such as information on payments to individuals and direct observation. The Inland Revenue estimated that their intelligence work identified at least £21.8 million additional yield in 1999-2000.[20]

22. The Inland Revenue have reorganised the way they approach intelligence work and in April 2001 set up specialised teams to improve the focus of this activity. They are also introducing a database to record the results of their intelligence work at national and local levels, and of specific initiatives. They accepted the Comptroller and Auditor General's finding that they had gaps in their management information, and needed to put in place quality assurance arrangements and performance targets. The database would help them ensure that the resources used were sufficient and well targeted, and to set targets and performance measures. Moreover, their Compliance Quality Initiative now provided a way of checking the quality of work done by their staff.[21]

23. Revenue had set up five pilot shadow economy teams with Customs and Excise, which were so successful that they rolled them out to a total of 20 teams in April 2001. These teams were identifying areas at risk, for example restaurants, which were cash businesses where lots of transactions could take place off the books. For the year 1999-2000, they settled enquiries into the returns of 505 restaurant businesses for a total tax yield (duties, interest and penalties in addition to the duties returned) of £3.44 million. From one specific project they had taken up 41 cases, finalised 13 and raised extra tax of £700,000. They also worked jointly with other agencies, for example the Benefits Agency to tackle specific groups such as gang masters in farming. In addition, they had targeted specific locations and businesses, such as stockbrokers to good effect and were conducting so called "leveraged trials" which targeted small traders.[22]

24. The Inland Revenue's improved risk analysis would help them target other risk areas, such as construction. The Construction Industry Scheme enabled them to identify a lot of builders, and when they investigated them they were particularly interested in jobs done for cash. In cases where money was going to people who were not within the Construction Industry Scheme, they could levy penalties and in extreme cases would prosecute. In judging whether to prosecute, they considered each case against published criteria including for example forgery, collusion, repeat offences and the status of the individual, such as a professional adviser.[23]

25. The Comptroller and Auditor General found that practice in New Zealand included five different strategies for identifying "ghosts" and "moonlighters": local intelligence, whistleblowers, data comparisons, special exercises on taxpayer groups such as builders, and a special audit unit. The Inland Revenue confirmed that they did all these things. As regards whistleblowers there was statutory provision for a reward system for those who informed them of any offence against any Act relating to the Inland Revenue.[24]

26. We asked why the yield from the Inland Revenue's intelligence activities had fallen from £30.6 million in 1998-99 to £21.8 million in 1999-00. They told the Committee that they did not target yield as such. They were moving away from only taking up cases where there was likely to be a yield and more towards bringing people into the legitimate economy - the right amount of tax from the right people. Risk and analysis teams would in future measure the number of ghosts and moonlighters that were brought into the tax system, which would knock on into all sorts of different yields. So while they did not target yield, they did forecast it and expected it to rise.[25]

(b) Access to and use of third party information

27. The Inland Revenue often based intelligence work on the analysis of third party information obtained using their statutory information powers. Their Taxes Information Distribution Unit obtains details of transactions, for example bank and building society interest, routinely from more than 12,000 sources, and much of this information is collated in a central data warehouse. Designated staff are able to obtain information relating to individuals in their area to support intelligence work.[26]

28. They also obtain other information in the public domain, for example property sales and the disposals of assets through auction houses, both routinely and as a result of specific local initiatives. This information is collated on a central database and is made available to intelligence staff in the local office network by CD-Rom supplied to Regional Offices.[27]

29. The Comptroller and Auditor General found that limited access to certain internal and third party information sometimes hampered intelligence work because the Inland Revenue's local Project Support System did not allow staff to share new approaches to intelligence activity or to track cases referred from one office to another. Staff therefore had to follow up referrals manually. This was a slow process and staff wasted time determining whether action had been taken or any additional tax identified and collected. In addition, local office staff were collating and analysing some information manually, as they lacked access to data collation and matching facilities.[28]

30. The Inland Revenue told the Committee that the Project Support System was a short term solution, while they worked on a fully integrated mainframe system. Their priority had been to update their main compliance IT system to support self assessment enquiry work. They had set up a new database to record the outcomes of this work on a nationally consistent basis, and staff no longer had to check manually with other areas to find out the results of a project which may have started and which then spread. The Project Support System was useful to the Random Inquiry Teams but it was still limited in scope, and the Inland Revenue were considering whether in the longer term they needed a more strategic system.[29]

31. The Comptroller and Auditor General also found that while some tax offices had access to all payment details held by local authorities on housing benefit, others only had access to details of named persons.[30] The Inland Revenue explained that under Section 18A of the Taxes Management Act 1970 they had access to all payment details held by local authorities in Housing Benefit, when they served a statutory notice. Some local authorities disputed their right to all details, but no local authority had refused to comply with a notice once the Inland Revenue had explained their legal entitlements. In order to overcome local discrepancies in obtaining information, the Inland Revenue were working towards a system for issuing standard notices to local authorities and handling the information received centrally. This was a long term project because local authorities held their information in different formats, often across different computer systems, and needed to put suitable IT in place to meet a standardised request.[31]

32. The Inland Revenue are continuing to develop their central data collation and matching facilities. From Summer 2001, they increased the scope and scale of automatic cross-checks between taxpayer declarations and third-party information, and confirmed that they were satisfied with the information they received from banks, building societies and other bodies who paid interest and dividends.[32]

(c) The effectiveness of enquiries into tax records

33. The Inland Revenue have new powers to enquire into tax returns under the self assessment system. They use these to deter and detect non-compliance. Local offices are required to prepare annual compliance plans and select cases for enquiry based upon an assessment of the risk to tax, which has made the process more comprehensive and structured. In addition, the introduction of mandatory reviews has introduced a greater uniformity in approach to higher risk aspects of individuals' tax affairs.[33]

34. In the first two years of the new arrangements, these random enquiries suggested that significant sums were at risk from non-declaration of income or gains. Their estimate for 1996-97 returns was £3 billion across self-assessment as a whole and for 1997-98, £1.8 billion. The Department is undertaking further enquiries on 1998-99 returns to obtain a firmer view of the amounts involved.[34]

35. Overall, the Inland Revenue expected to make real inroads into these sums at risk refining their indicators of risk, getting in more returns and more tax, augmenting the activities of their risk, intelligence and assessment teams, developing simpler forms, and helping businesses through support teams. In particular, better, more refined risk assessments would help them target their efforts better.[35]

36. The Inland Revenue had 3,192 full time equivalent staff carrying out enquiries into self assessment tax returns in 1999-2000 at a cost of £216.1 million.[36] They had set quantitative and qualitative targets for compliance work at national, regional and local level. They had since refined and developed these targets to focus on more rounded measures of compliance activity, and to target risk as well as having a basic level of coverage overall. They were also seeking to tackle resourcing problems, which had led to slippage in their compliance programme in some areas, such as London.[37]

(d) Lessons learned from best practice overseas

37. In looking at the Inland Revenue's operation of the self assessment system, the Comptroller and Auditor General drew on experience overseas, for example in Australia, New Zealand and Canada.[38]

38. The Inland Revenue confirmed that they were keen to learn from other countries, although no two-tax systems were the same. They had a model of compliance activity taken from Australia. Their strategic planners had been directly influenced by what they found in the United States and Canada, and they had asked the Canadian Customs and Revenue Authority to conduct a peer review of their business planning system, because they were the world leaders in that field. In addition, the Inland Revenue's receivables management system had been developed as part of a joint study with Australia, New Zealand, the United States, Canada and Japan.[39]

39. More widely, the Chairman of the Inland Revenue was a member of the OECD's Strategic Management Forum, the head of their international division chaired the Council for Fiscal Affairs of the OECD, and the Revenue also chaired the Electronic Commerce Specialist Group. They were stepping up this work because of the globalisation of the economy and the various implications of more electronic commerce, which made it even more important to know what other countries were doing.[40]


40. One of the Inland Revenue's aims is to administer the tax system fairly and efficiently and make it as easy as possible for people and businesses to understand and comply with their obligations. One of their objectives is to deliver year on year reductions in compliance costs that act as a barrier to the growth of small businesses. Their objectives for self assessment are to increase taxpayer understanding and compliance, to maintain the flow of funds to the Exchequer and to produce cost and resource savings.[41]

41. We therefore asked the Inland Revenue what they were doing to make the tax system as simple and as easy to use as possible, and in particular to help those who might find self-assessment difficult.[42] They told the Committee they were laying much more emphasis on the Revenue as an enabling as well as a regulating department, and that meant devoting a more conscious effort to helping people get it right. For example, a pensioner or anyone else in difficulty could ring their helpline or call in at their local office. And as regards people with other languages, they provided forms and leaflets in 10 languages, and would provide access to people who could speak in other languages where that was required.[43]

Figure 4: Languages in which the Inland Revenue provide forms and leaflets

42. They recognised that some aspects of the self assessment system were still not user friendly. They thought the greatest area of concern was the understanding of the forms and guidance, and they had done a lot to improve these, drawing on feedback from taxpayers. Important outputs included the tax return pack, which included the tax return guide and the tax calculation guide. They had also simplified the statement of account, and were looking to simplify it further working with representatives of taxpayers and, importantly, with tax agents and their representatives. They had appointed a Marketing Communications Director to try to understand the groups their customers fell into, their needs and where improvements were required. They were working very closely with Citizens Advice Bureaux, the Low Income Tax Reform Group, the Institute of Chartered Accountants and the Chartered Institute of Taxation. For example, with the latter groups they had a joint exercise - the Working Together Initiative - specifically to log processing difficulties and to look at them.[44]

43. As regards simplification of the tax system, Ministers were aware of the feedback from the accountancy bodies and from small businesses. The Inland Revenue devoted a great deal of time and effort to trying to simplify things. They had small business teams working all over the country working jointly with Customs and Excise to make it easier to set up small businesses. They had restructured their organisation into 60 areas each with one director looking at compliance and another dealing with services. As a result, they were better placed to focus on the communities they served, to be outward facing, in touch with their local Chambers of Commerce and with small businesses. There were examples, such as the new share schemes devised in 2000, where the Government had leant very heavily on the advice of the private sector, trade unionists and practitioners but people still complained of complexity.[45]

1   C&AG's Report, para 1 Back

2   C&AG's Report, Inland Revenue: Income Tax Self Assessment (HC 56, Session 2001-02) Back

3   C&AG's Report, para 5 and Appendix 2, paras 2-3 Back

4   The Informal Economy: A Report by Lord Grabiner QC , para 1.15 Back

5   C&AG's Report, para 5 and Appendix 2 (not printed here); Qs 2, 11-13, 71-72 Back

6   Q72; Handbook for Measurement of Non-Observed Economy, para 1.27 (not printed here) Back

7   C&AG's Report, para 5, Figure 15, and Appendix 2; Qs 3-4, 16, 21-22 Back

8   C&AG's Report, para 5 and Appendix 2, paras 6-7 and Figure 15 Back

9   C&AG's Report, para 3.1 Back

10   ibid, paras 3.3-3.4 and Figure 10 Back

11   Qs 48-51, 112-114, 123-124, 140-142 Back

12   Qs 28-29 Back

13   Qs 7, 30-31, 37-45, 61-62, 190-191; Ev, Appendix 1, p29 Back

14   C&AG's Report, paras 3.2, 3.8 Back

15   C&AG's Report, paras 3.2, 3.8; Qs 60, 128-136, 174-187, 285-287; Ev, Appendix 1, p32 Back

16   C&AG's Report, paras 3.5, 3.8; Qs 135-137, 171-173, 185-187 Back

17   C&AG's Report, paras 3.2, 3.8  Back

18   Qs 7, 109, 136-137 Back

19   Qs 8, 138-139 Back

20   C&AG's Report, paras 11, 2.7-2.10 and Figures 6-8 Back

21   C&AG's Report, paras 12, 2.14; Qs 5-6 Back

22   C&AG's Report, Appendix 2; Qs 73-74, 79-81, 214-217, 228-237 Back

23   Qs 27, 32-35, 218-220; Ev, Appendix 1, p29 Back

24   C&AG's Report, Appendix 3, para 10; Qs 77-78; Ev, Appendix 1, p29 Back

25   Qs 5, 36, 82-84, 258 Back

26   C&AG's Report, para 2.9  Back

27   ibid, para 2.10  Back

28   ibid, para 2.11  Back

29   Qs 85-89 Back

30   C&AG's Report, para 2.11  Back

31   Qs 90-95, 221-227; Ev, Appendix 1, p29 Back

32   C&AG's Report, para 2.12; Qs 221-227 Back

33   C&AG's Report, para 15 Back

34   C&AG's Report, para 16 and Appendix 2; Qs 3-4, 16, 21-22 Back

35   Qs 10, 15, 278-281  Back

36   Q167 (footnote) Back

37   C&AG's Report, paras 4.9-4.11 and Figures 13, 14; Qs 22-26, 147-169  Back

38   C&AG's Report, paras 6, 1.9 and Appendix 3 Back

39   Q17 Back

40   Q18 Back

41   C&AG's Report, paras 1.5; The Government's Expenditure Plans 2001-04, Cm 5118 - March 2001  Back

42   Q58 Back

43   Qs 9, 276-277; Ev, Appendix 1, p32 Back

44   Qs 19-20, 56-57, 65-67, 96-101 Back

45   Qs 58-59 Back

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