1. My name is Patrick J. Lynch.  

   2. I live in the State of Pennsylvania, at 2 East Abbott Street, Lansford, postal zip 18232.  

   3. In the past 12 years I have spent approximately 12,000 hours in studying documents and codes related to the Individual Master File.  The following represents a partial list of the materials I have studied;  

Internal Revenue Code, Regulations and Statutes, 1866 to present.  

Internal Revenue Manuals;  

ADP IDRS Document 6209, Revision 1976 through Revision 1997. Law Enforcement Manual III,  IRM 3(27)(68)0

Audit Information Management System, AIMS, IRM 48(13)1,2 and 3.

IRS Handbook for Special Agents, MT 9781.

Substitute For Return Handbook, IRM 5480.

Delinquent Return Procedures, IRM 5200.

Balance Due Account Procedures, IRM 5300.

Service Center Collection Branch Procedures, IRM 5400.

Collection Field Function Technical & Other, IRM 5600.

Special Procedures, IRM 5700.

United States Attorneys' Manual, Tax Division.  

   4. I have aided several Assistant Federal Public Defenders and private attorneys over the past eleven years in the capacity as an expert on deciphering and understanding Internal Revenue Service internal code applications and in criminal cases brought by the United States concerning tax matters.  

Representative cases include:  

   United States v. Daniel Chanlee,  Richard Coglin was the Public Defender.  This case was tried in Camden, New Jersey, in 1988.  

   United States v. Ronald Driggers,  Joel Johnson was the Public Defender and Carl Max Janavitz was the private attorney involved.  This case was tried in Pittsburgh, Pennsylvania, in 1989.  

   United States v. George Edwards,  CA# 90-121, David E. Schafer was the Public Defender. This case was tried in Trenton, New Jersey, in 1993.  

   United States v. William T. Davis, CA# 4:97-682, William White Jr. and Hamilton McMenamy were the private attorneys involved. This case was tried in Florence, South Carolina, January, 1998.