[Federal Register Volume 60, Number 171 (Tuesday, September 5, 1995)]
[Notices]
[Pages 46141-46145]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 95-21909]
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DEPARTMENT OF THE TREASURY
Notice to Test the Use of Reconciliation for Adjustments Made to
the Price of Imported Merchandise by Related Party Companies under 26
U.S.C. 482
AGENCY: Customs Service, Department of the Treasury.
ACTION: Final notice.
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SUMMARY: This notice announces Customs plan to conduct a test regarding
the use of reconciliation for those related party importers which have
reason to believe upward adjustments may be made to the price of
imported merchandise for tax purposes pursuant to 26 U.S.C. 482. This
notice invites public participation in the test, and sets out the
eligibility requirements for voluntary participation in the testing of
reconciliation, for this purpose, and describes the basis on which
Customs will select participants.
DATES: The test will commence no earlier than October 1, 1995, and will
run until December 31, 1996. To participate in this reconciliation
test, the application must be filed and approved by Customs on or
before October 1, 1995.
ADDRESSES: To be considered for voluntary participation in this test
applications should be submitted to Mr. William F. Inch, Director,
Office of Regulatory Audit, Office of Strategic Trade, U.S. Customs
Service, 1301 Constitution Avenue, NW., Room 2311, Washington, DC
20229-0001.
FOR FURTHER INFORMATION CONTACT: Matthew Krimski 202-927-0411.
SUPPLEMENTARY INFORMATION:
Background
Section 1059A of the Internal Revenue Code
Section 1059A of the Internal Revenue Code provides that in related
party transactions the amount of any costs--
(1) Which are taken into account in computing the basis or
inventory cost of such property by the purchaser, and
(2) Which are also taken into account in computing the customs
value of such property shall not, for purposes of computing such basis
or inventory cost for purposes of this chapter, be greater than the
amount of such costs taken into account in computing such customs
value.
The legislative history of section 1059A indicates that Congress
intended to preclude the ``whipsaw'' effect on U.S. revenue which
occurs when a party is allowed to claim a price for ``computing the
customs value of such property by the purchaser'' that is lower than
the price claimed for tax purposes.
When section 1059A was enacted, Congress was aware that the Customs
value statute recently had been amended to make price paid the critical
cost factor taken into account by the Customs Service in valuing goods
for duty purposes. The legislative history of section 1059A also
indicates that Congress wanted section 1059A to address this situation
by attempting to place a ceiling on ``the amount of any (such) costs''
that can be claimed for tax purposes. All of the applicable legislative
reports indicate, without exception, that Congress intended that
section 1059A would instill some uniformity on the amount of costs
which may be claimed to the IRS for tax purposes by limiting the amount
of such costs to the amount claimed to, and taken into account by, the
Customs Service in computing the Customs value.
The legislative history did state that appropriate adjustments may
be made in cases where customs pricing rules differ from appropriate
tax rules--as, for example, with the inclusion or exclusion of freight
charges. Finally, the history states section 1059A applies to transfer
prices subject to section 482 of the Internal Revenue Code.
In July of 1994, the Internal Revenue Service (IRS) issued final
regulations implementing 26 U.S.C. 482. The IRS subsequently began
considering whether and to what extent the 1059A regulations should be
amended in the context of the new section 482 regulations. The section
482 regulations, specifically 26 CFR 1.482-1(a)(3), permits a
controlled taxpayer, if necessary to reflect an ``arm's length
result,'' to ``report on timely filed U.S. income tax return (including
extensions) the results of its controlled transactions based upon
prices different from those actually charged.'' The IRS is considering
whether the 1059A regulations should be amended to allow the taxpayer,
under appropriate circumstances, to make the upward section 482
adjustment.
This document announces a test that will facilitate the IRS/Customs
decision
[[Page 46142]]
as to whether reconciliation procedures provide a viable and
appropriate circumstance for a taxpayer/importer to make a post entry
upward adjustment to the price of imported merchandise.
Customs Value Law
For Customs purposes the appraised value of imported merchandise is
determined pursuant to section 402 of the Tariff Act of 1930, as
amended by the Trade Agreements Act (TAA) of 1979. Transaction value is
the primary basis of appraisement. Transaction value is defined in
section 402(b)(1) as the ``price actually paid or payable for the
merchandise when sold for exportation to the United States'' plus
specified statutory additions.
Pursuant to section 402(b)(2)(A)(iv) the transaction value of
imported merchandise shall be the appraised value only if the buyer and
seller are not related, or if the buyer and the seller are related, the
transaction value is acceptable under 402(b)(2)(B). Section
402(b)(2)(B) provides that transaction value between a related buyer
and seller is acceptable if the buyer demonstrates that the declared
transaction value meets one of the following two tests: (1)
Circumstances of the Sale or (2) Test Values.
The reconciliation test, announced in this document, is designed
for participants that engage in related party transactions.
Related Party Transactions
Under section 402(g) of the TAA the following persons are treated
as related:
(1) Members of the same family, including brothers and sisters
(whether by whole or half blood), spouse, ancestors, and lineal
descendants.
(2) Any officer or director of an organization and such
organization.
(3) An officer or director of an organization and an officer or
director of another organization, if each such individual is also an
officer or director in the other organization.
(4) Partners.
(5) Employer and employee.
(6) Any person directly or indirectly owning, controlling, or
holding with power to vote, 5 percent or more of the outstanding voting
stock or shares of any organization and such organization.
(7) Two or more persons directly or indirectly controlling,
controlled by, or under common control with, any person.
For purposes of 402(g)(G), the phrase ``two or more persons
directly or indirectly controlling, controlled by, or under common
control with, any person'' is understood to cover the following
situations:
(1) Where one of them directly or indirectly controls the other;
(2) Where both of them are directly or indirectly controlled by a
third person; or
(3) Where together they directly or indirectly control a third
person.
For purposes of this test, Customs will consider the fact that the
related party importer has reason to believe that an upward adjustment
may be made to the price as evidence that the relationship may have
affected the price actually paid or payable for the imported
merchandise. Therefore, transaction value may not be acceptable.
Rather, the merchandise may be appraised under section 402(f). The
appraised value pursuant to section 402(f) will be derived from the
transaction value method. That is, the appraised value will be the
price for the imported merchandise after the upward section 482
adjustment is undertaken by the importer/taxpayer plus the applicable
statutory additions: Packing, selling commissions, assists, royalties/
license fees and proceeds of subsequent resale. In order to participate
in the test, the importer/taxpayer must agree that 402(f) is the proper
basis of appraisement, in the event an upward section 482 adjustment
is, in fact, claimed for tax purposes.
Title VI of the North American Free Trade Agreement Implementation Act
In order for the importer to comply with Customs value law, when
making upward adjustments, a mechanism must be established that permits
the importer to submit information related to the upward adjustment
after the time of entry. Customs has determined that the reconciliation
provisions of the North American Free Trade Agreement Implementation
Act (the Act) create a possible vehicle permitting these circumstances.
Specifically, Title VI of the Act, Public Law 103-182, 107 Stat. 2057
(December 8, 1993), contains provisions pertaining to Customs
Modernization (107 Stat. 2170). Subtitle B of Title VI establishes the
National Customs Automation Program (NCAP), an automated and electronic
system for the processing of commercial importations. Section 637 in
Subtitle B of the Act amends section 484 of the Tariff Act of 1930 by
establishing a new subsection (b) entitled ``Reconciliation''.
Reconciliation is a planned component of the NCAP. Section 631 of the
Act authorizes tests of planned NCAP components. Section 101.9(b) of
the Customs Regulations, provides the regulations governing the testing
of NCAP components. See T.D. 95-21 (60 FR 14211, March 16, 1995).
This test is established pursuant to those regulations.
Reconciliation
Reconciliation will allow an importer to provide Customs with
information not available at the time of entry summary filing and which
is necessary to ascertain the final classification and appraisement of
imported merchandise. The reconciliation must be filed no later than 15
months from the date of the first entry summary filed under that
reconciliation.
A reconciliation permits the liquidation of an entry summary/
summaries despite the fact that undetermined information will be
transmitted to Customs at a later time through the reconciliation
process. Assuming there are no other outstanding issues, the entry
summaries will be liquidated for all purposes other than that which is
identified by the importer as pending reconciliation. The
reconciliation will be liquidated in accordance with 19 U.S.C. 1500.
The liquidation of the reconciliation may be protested, in accordance
with 19 U.S.C. 1514, but the protest may only pertain to issues covered
by the liquidated reconciliation.
A draft notice was published requesting comments from interested
parties on July 5, 1995. We received ten comments and the following is
Customs analysis and response to those comments.
Discussion of Comments
Bond Requirement
Comment: The commenter, a surety company, states that language
should be added to clearly define the bond requirements for the
reconciliation entry.
Customs Response: All entries which are pending reconciliation must
be secured by a continuous bond. Customs will allow only one surety for
all entries under the reconciliation. If a participant changes sureties
during the reconciliation period, Customs must be notified before the
change is actually made. No additional entries will be added to the
first reconciliation, and a new reconciliation entry will be initiated.
In this situation, Customs will issue a separate reconciliation entry
number for the future entries to be filed during the remainder of the
reconciliation period. Both reconciliation summaries will be due at the
close of the reconciliation period.
A separate bond will not be required for the reconciliation entry.
The continuous bond on the subject entries will provide coverage for
the
[[Page 46143]]
reconciliation entry. The Basic Importation and Entry Bond Conditions
under 19 CFR 113.62 provide for an agreement of the principal and
surety to pay, as demanded by Customs, all additional duties, taxes,
and charges subsequently found due, legally fixed, and imposed on any
entry secured by the bond. The bond conditions as prescribed by
regulation also provide for agreement by the principal to file within
the time and in the manner prescribed by law and regulation,
documentation to enable Customs to properly assess duties on the
merchandise, collect accurate statistics with respect to the
merchandise, and determine whether applicable law and regulation are
met.
Bond Sufficiency
Comment: The commenter, a surety company, is concerned that a
continuous bond may not adequately cover the amount due on the
reconciliation entry.
Customs Response: For purposes of this test, Customs believes the
continuous bond for the entry summaries will adequately cover the
amount due on the reconciliation entry. Customs will monitor each
reconciliation individually and should additional coverage be deemed
necessary, it will be requested. Customs is conducting research into
bond sufficiency from the standpoint of the Chief Financial Officers
Act, with respect to all programs under the Mod Act.
Notice to Sureties
Comment: The commenter, a surety company, states that Customs must
notify the surety bonding the entries subject to reconciliation that
the importer is using reconciliation. Accordingly, the commenter
suggests that Customs advises the surety, electronically if possible,
as to which entries are subject to reconciliation as well as the
specific issue pending reconciliation.
Customs Response: Upon acceptance into this reconciliation
prototype, Customs will issue a confirmation letter to the participant.
This letter will provide the reconciliation entry number which is to be
utilized. In this document, Customs will also confirm that all entries
filed on behalf of the applicant, within the designated time frame,
meeting the scope as defined by the applicant, will be subject to
reconciliation of the entered value pending upward adjustments in
accordance with 26 U.S.C. 482. A courtesy copy of this confirmation
letter will be sent to the surety company, which is designated in the
application. This will serve as the notice to the surety that all
entries filed within the designated time frame, meeting the scope as
defined by the applicant, will be subject to reconciliation of the
entered value. The value element on the subject entries will be
liquidated on the reconciliation entry.
Identification of Reconciliation
Comment: The commenter, a surety company, asks how Customs will
identify such reconciliation.
Customs Response: Each reconciliation will be identified by a
separate entry number issued by Customs.
Scope of Reconciliation
Comment: The commenter, a surety company, is concerned that Customs
will be withholding liquidation pending reconciliation of the valuation
on all entries filed by the applicant, when in fact, not all
merchandise on those entries may be subject to the possible upward
adjustment.
Customs Response: For the purposes of this reconciliation
prototype, the importer is required to provide, in the application, the
scope of the reconciliation. The scope will be defined in the
application to include the importer, filer, surety, merchandise (by
Harmonized Tariff Schedule number) which will be subject to the
reconciliation, and reconciliation time frame (October 1, 1995 through
March 31, 1996, or the end of their tax year, whichever comes first).
During the reconciliation period, the entered value, with respect to
upward 482 adjustments, on the entries meeting the designated scope
criteria will be held open pending the reconciliation.
Liquidation
Comment: The commenter, a surety company, requests information
regarding the liquidation of the reconciliation.
Customs Response: The reconciliation is an entry, identified by
entry type 09. The reconciliation will permit the liquidation of the
entries despite the fact that the undetermined value information will
be provided to Customs at a later time. Upon liquidation of the
entries, any Customs decision entering into that liquidation, e.g.,
classification, may be protested pursuant to 19 U.S.C. 1514. When the
value information is provided in the reconciliation, the reconciliation
will be treated as an entry and liquidated. The liquidation of the
reconciliation may also be protested but the protest may only pertain
to elements contained in the liquidated reconciliation, i.e., the
protest may not re-visit elements previously liquidated in the entries.
Customs will take action to liquidate all reconciliation entries
filed pursuant to this prototype, and extend the liquidation if
necessary. Should the reconciliation NOT be filed, the importer will be
subject to liquidated damages as the terms of the bond have been
breached. In such a case, Customs will analyze the individual situation
and liquidate the reconciliation appropriately.
Possible Abuse of Reconciliation
Comment: The commenter, a surety company, states that Customs
should limit the number of reconciliations an importer can use, so as
to avoid separate reconciliations for each issue for each entry.
Customs Response: For the purposes of this test, the only element
open for reconciliation is valuation, specifically an adjustment to the
price made to comply with 26 U.S.C. 482. Customs will be able to
adequately monitor the amount of reconciliations requested through the
application process. The intent of the reconciliation is to link all
entries with common, undetermined value information to one
reconciliation entry.
Expansion to Include Downward Adjustments
Comment: The test should be expanded to include both upward and
downward adjustments.
Customs Response: This test is designed to address a specific issue
identified by the Internal Revenue Service. That is, if an importer
must make an upward adjustment to its transfer price in order to comply
with 26 U.S.C. 482, section 1059A acts as a bar to such adjustment if
the lower price was declared to Customs. The section 1059A bar does not
apply to situations in which the importer contemplates making a
downward adjustment to the price. Given the restricted scope of the
test, Customs has concluded that the test will continue to be limited
to importers that contemplate making an upward adjustment to their
transfer prices to comply with 26 U.S.C. 482. However, Customs is
analyzing whether downward adjustments to prices can and should be
addressed in future reconciliation tests.
Bases of Appraisement
Comment: There is no reason why section 1401a(a)(I)(f) must be the
applicable basis of appraisement in the proposed test.
Customs Response: As was stated in the initial notice, Customs
considers the
[[Page 46144]]
fact that the related party importer has reason to believe that an
upward adjustment may be made to the price of the imported merchandise
as evidence that the relationship may have affected the price actually
paid or payable for the merchandise. Therefore, transaction value will
not be considered to be the proper basis of appraisement. The importer
continues to have the right to have the hierarchy of appraisement
applied to its transactions. However, if the importer claims another
basis of appraisement, such as deductive value, then the importer will
not be able to participate in the proposed test. This is due to the
fact that the test is designed to determine how Customs can use the
prices that the importer paid to the seller and the upward adjustments
to those prices by using reconciliation. If a basis of appraisement is
used that does not use these adjusted prices then the information is
meaningless, for purposes of this test. Appraisement under section
402(f) of the Tariff Act of 1930, as amended by the Trade Agreements
Act of 1979 allows Customs to utilize the importer's information on the
price it paid, and to reasonably appraise the merchandise using that
information.
Providing Customs With IRS Form 5472
Comment: One commenter responded with a suggestion that the
Internal Revenue Service routinely provide the U.S. Customs Service
with the IRS Form 5472 which requests information on import
transactions and the related party status of the exporter/importer. The
information on the Form 5472 would identify differences between the
basis or inventory costs of imported goods as carried for IRS purposes
and the Customs value of the imported goods. If such differences did
exist, IRS Form 5472 requires an explanation for such differences and
if supporting documentation exists in the United States.
Customs Response: Under existing IRS confidentiality statutes, the
routine transfer of IRS information to the U.S. Customs Service is
prohibited. Only in cases where the Customs Service has a Customs
Regulatory Audit planned or in progress, can Customs request certain
specific information from the IRS and only in cases when the importer
has refused to provide the information voluntarily. The existing
provisions for these transfers are contained in Public Law 103-182
passed December 8, 1993.
Description of Test
This test will be limited to participants who meet the eligibility
criteria set forth below. It will cover entry summaries filed by those
participants from October 1, 1995 to March 31, 1996 or the end of the
participant's tax year, whichever comes first. Each reconciliation is
limited to one importer/filer/surety combination.
By statute, reconciliation must be filed within 15 months of the
entry summary. The reconciliation entry (i.e. the intent to file the
reconciliation) is considered filed when the application is submitted
to Customs. For purposes of this test, participants must file the
reconciliation summary, which provides the outstanding value
information, within 15 months of the filing of the first affected entry
summary or by December 31, 1996, whichever comes first. All
reconciliation entries will be filed to the attention of Matthew
Krimski, Office of Regulatory Audit, Office of Strategic Trade, U.S.
Customs Service, 1301 Constitution Avenue, NW, Washington, DC 20229.
Customs will advise participants where additional duties resulting from
the reconciliation are to be tendered.
All entries which are pending reconciliation must be secured by a
continuous bond. Customs will allow only one surety for all entries
under the reconciliation. If a participant changes sureties during the
reconciliation period, Customs must be notified before the change
actually is made. No additional entries will be added to the first
reconciliation, and a new reconciliation entry will be initiated. In
this situation, Customs will issue a separate reconciliation entry
number for the future entries to be filed during the remainder of the
reconciliation period. Both reconciliation summaries will be due at the
close of the reconciliation period.
The continuous bond on the subject entries will provide coverage
for the reconciliation entry. The Basic Importation and Entry Bond
Conditions under 19 CFR 113.2 provide for an agreement of the principal
and surety to pay as demanded by Customs all additional duties, taxes,
and charges subsequently found due, legally fixed and imposed on any
entry secured by the bond. The bond conditions as prescribed by
regulation also provide for agreement by the principal to file within
the time and in the manner prescribed by law and regulation,
documentation to enable Customs to properly assess duties on the
merchandise, collect accurate statistics with respect to the
merchandise and determine whether applicable law and regulation are
met.
The reconciliation is an entry identified by entry type 09. The
reconciliation will permit the liquidation of the entries despite the
fact that the undetermined value information will be provided to
Customs at a later time. Upon liquidation of the entries, any Customs
decision entering into liquidation e.g. classification, may be
protested pursuant to 19 U.S.C. 1514. When the value information is
provided in the reconciliation, the reconciliation will be treated as
an entry and liquidated. The liquidation of the reconciliation also may
be protested, but the protest may only pertain to elements contained in
the liquidated reconciliation, i.e. the protest may not re-visit
elements previously liquidated in the entry.
Note: In those cases in which the Harmonized Tariff Schedule
(HTS) classification is determined by the unit value, the
classification for those commodities also will be held open pending
the reconciliation.
Customs will take action to liquidate all reconciliation entries
filed pursuant to this prototype and extend the liquidation if
necessary. Should the reconciliation not be filed, the importer will be
subject to liquidation damages as the terms of the bond have been
breached. In such cases, Customs will analyze the individual situation
and liquidate the reconciliation appropriately.
Application
Applications will be submitted to Mr. William F. Inch, Director,
Office of Regulatory Audit, United States Customs Service, 1301
Constitution Ave. NW., Room 2311, Washington, DC 20229-0001. All
applicants will be notified in writing of approval or disapproval
regarding test participation. All applicants who meet the eligibility
criteria will be chosen to participate in this test. The application
must address the ability to meet the eligibility requirements. The
applicant must consent, in the application, to all the conditions set
forth in the description of this test and eligibility criteria. The
applicant must set forth in the application the date on which the
applicant's tax year ends. The following information must be included
in the application:
1. Importer and IR number;
2. Filer;
3. Surety;
4. Reconciliation Time frame (October 1, 1995 through end of tax
year or March 31, 1996, whichever comes first;
5. Merchandise, by Harmonized Tariff Schedule number, impacted by
the possible 482 adjustment;
6. Countries of origin of impacted merchandise; and
7. Ports of entry through which the subject merchandise will be
imported during the reconciliation period.
[[Page 46145]]
By applying, applicants agree that the value for merchandise
covered by all entry summaries filed by them or on their behalf on or
after October 1, 1995 until the end of the tax year or March 31, 1996,
whichever comes first, shall be finally determined by the liquidation
of the reconciliation filed in accordance with the test. The Office of
Regulatory Audit will review the application to determine that the
applicant has met all eligibility requirements.
Documentation Required to Support Reconciliation
The approved participant shall maintain and produce upon Customs
request all relevant documentation to support the change in the entered
value. The reconciliation shall include the following information:
1. The entry numbers and entry dates, total entered value and ports
of entry of all entries filed with Customs falling within the scope of
the test.
2. Broken down by entry number, a cumulative list of units imported
by classification number and the change (final entered value) to that
entered value.
3. Proposed duty due pursuant to reconciliation.
In order to support the reconciliation, the approved applicant
shall maintain and produce upon Customs request all relevant
documentation to support the change in entered value. The approved
applicant may be required to provide any or all of the following
documentation:
1. The IRS Schedule M-1, and the Form 1120 Corporate Tax Return.
2. Any and all other supporting documentation filed along with the
M-1 and the Form 1120 that was furnished to the IRS.
3. Any or all IRS documents or communications with the participant
regarding the relevant 482 adjustment.
4. Any and all documentation including any books and records or
computerized data to relate the 482 adjustment to the entries filed
with Customs.
Such information and supporting material should be provided in a
format or electronic media commonly in use. Examples are an IBM
compatible computer 3.5 disk utilizing a software product such as
Access or Excel or other similar spreadsheet or database application
such as Lotus 1, 2, 3.
Verification
Customs Regulatory Audit, in conjunction with other Customs
disciplines, will determine if any verification effort is necessary to
establish the accuracy of the details submitted. The extent of the
verification will be determined by Regulatory Audit, and if an audit is
required, established Regulatory Audit procedures will be followed.
Eligibility Criteria
In order to qualify for this test of reconciliation, importers must
have reason to believe they may invoke the IRS regulations to make
upward adjustments to the price of the imported merchandise. Importers
must provide, on an entry-by-entry basis, the electronic entry of
merchandise and the electronic entry summary of required information
(ABI). Other requirements and conditions are as follows:
1. The test only applies to the related party transactions engaged
in by participants who qualify under Internal Revenue Service Section
482 requirements to make upward adjustments and which are not subject
to Antidumping/Countervailing Duty proceedings.
2. Participants' tax year must end between October 31, 1995 and
March 31, 1996.
3. Customs decision to allow a company to participate in the test
program will be made in consultation with the Internal Revenue Service.
4. Each participant must provide U.S. Customs with the methodology
that will be used to arrive at the final price of the imported
merchandise.
5. Each participant agrees that appraisement is under section
402(f) of the Tariff Act of 1930, as amended by the Trade Agreements
Act of 1979, if, in fact, an upward section 482 adjustment is made for
tax purposes.
6. Entries involving merchandise under this test will not be
eligible for drawback.
Selectivity Criteria
The Office of Regulatory Audit, in conjunction with other Customs
disciplines, will review the application to ensure the eligibility
requirements are met. All applicants who meet the eligibility criteria
will be allowed to participate, provided no other Customs office
objects.
Objectives of the Test
The objectives of this test are:
1. To work with the trade community to further compliance in the
value area regarding related party transactions.
2. To allow companies intending to make Internal Revenue Service
Section 482 adjustments, which may ultimately result in an upward
adjustment to the price for merchandise, the opportunity to reconcile
their business operations regarding U.S. Customs and Internal Revenue
Service requirements applicable to related party transactions.
3. To determine if reconciliation is a viable method to ensure a
coordinated and consistent Customs response to Internal Revenue Section
482 adjustments which result in the upward adjustment of the Customs
valuation under Section 1059A.
5. To test the type of information needed by Customs to process a
reconciliation.
Test Evaluation Criteria
The criteria which will be used to evaluate whether or not
reconciliation is a viable means to allow importers which make upward
adjustments to the price of imported merchandise will be based on
measurable outcomes which include:
1. The number of participants;
2. Customs resources expended to administer and monitor the
program;
3. Customs resources expended to verify final reconciliation entry
claims and the methodologies applied;
4. Amount of additional revenue collected;
5. Survey of participants on the conduct of the test and its effect
on their business operations; and
6. IRS and Census satisfaction with the results of the test.
Dated: August 30, 1995.
Edward F. Kwas,
Assistant Commissioner, Office of Strategic Trade.
[FR Doc. 95-21909 Filed 9-1-95; 8:45 am]
BILLING CODE 4820-02-P
