South Dakota V. Wayfair, Inc.: Online Sales Taxes and Their Impact on Main Street (House Small Business Committee hearing, March 3, 2020)
Summary
The printed record of a hearing, South Dakota v. Wayfair, Inc.: Online Sales Taxes and Their Impact on Main Street, held March 3, 2020 by the Subcommittee on Economic Growth, Tax, and Capital Access of the House Committee on Small Business, Small Business Committee Document Number 116–075. Hon. Andy Kim and Hon. Kevin Hern gave opening statements. Four witnesses testified: Jamie Yesnowitz, Principal at Grant Thornton, LLP, for the American Institute of Certified Public Accountants; Linda Lester, Vice President of K-Log, Inc., Zion, IL; Kevin Mahoney, President and Founder of FindTape.com, North Brunswick, NJ; and Brad Scott, Financial Director of Halstead Bead, Inc., Prescott, AZ. The appendix carries their prepared statements, Scott's running from page 115, and additional material including a statement of Matthew Behnke, President of Orthotic Shop Inc.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Cite this document
“South Dakota V. Wayfair, Inc.: Online Sales Taxes and Their Impact on Main Street (House Small Business Committee hearing, March 3, 2020).”
Original at www.govinfo.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/south-dakota-v-wayfair-inc-online-sales-taxes-and-their-impact-on-main-280a3cc750/
, SHA-256 0f348e162f95d80c17cf3580f3deb665be90b8d4b1b66288fad26c79d9eeb69c.Full text
SOUTH DAKOTA V. WAYFAIR, INC.: ONLINE SALES
TAXES AND THEIR IMPACT ON MAIN STREET
HEARING
BEFORE THE
COMMITTEE ON SMALL BUSINESS
UNITED STATES
HOUSE OF REPRESENTATIVES
ONE HUNDRED SIXTEENTH CONGRESS
SECOND SESSION
HEARING HELD
MARCH 3, 2020
Small Business Committee Document Number 116–075
Available via the GPO Website: www.govinfo.gov
SBD026 with DISTILLER
Congress.#13
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00001 Fmt 6011 Sfmt 6011 F:\DOCS\39857.TXT DEBBIE
SOUTH DAKOTA V. WAYFAIR, INC.: ONLINE SALES TAXES AND
THEIR IMPACT ON MAIN STREET
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00002 Fmt 6019 Sfmt 6019 F:\DOCS\39857.TXT DEBBIE
SOUTH DAKOTA V. WAYFAIR, INC.: ONLINE SALES
TAXES AND THEIR IMPACT ON MAIN STREET
HEARING
BEFORE THE
SUBCOMMITTEE ON ECONOMIC GROWTH,
TAX, AND CAPITAL ACCESS
OF THE
COMMITTEE ON SMALL BUSINESS
UNITED STATES
HOUSE OF REPRESENTATIVES
ONE HUNDRED SIXTEENTH CONGRESS
SECOND SESSION
HEARING HELD
MARCH 3, 2020
Small Business Committee Document Number 116–075
Available via the GPO Website: www.govinfo.gov
U.S. GOVERNMENT PUBLISHING OFFICE
39–857 WASHINGTON : 2020
SBD026 with DISTILLER
Congress.#13
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00003 Fmt 5011 Sfmt 5011 F:\DOCS\39857.TXT DEBBIE
HOUSE COMMITTEE ON SMALL BUSINESS
NYDIA VELÁZQUEZ, New York, Chairwoman
ABBY FINKENAUER, Iowa
JARED GOLDEN, Maine
ANDY KIM, New Jersey
JASON CROW, Colorado
SHARICE DAVIDS, Kansas
JUDY CHU, California
MARC VEASEY, Texas
DWIGHT EVANS, Pennsylvania
BRAD SCHNEIDER, Illinois
ADRIANO ESPAILLAT, New York
ANTONIO DELGADO, New York
CHRISSY HOULAHAN, Pennsylvania
ANGIE CRAIG, Minnesota
STEVE CHABOT, Ohio, Ranking Member
AUMUA AMATA COLEMAN RADEWAGEN, American Samoa, Vice Ranking Member
TROY BALDERSON, Ohio
KEVIN HERN, Oklahoma
JIM HAGEDORN, Minnesota
PETE STAUBER, Minnesota
TIM BURCHETT, Tennessee
ROSS SPANO, Florida
JOHN JOYCE, Pennsylvania
DAN BISHOP, North Carolina
MELISSA JUNG, Majority Staff Director
JUSTIN PELLETIER, Majority Deputy Staff Director
KEVIN FITZPATRICK, Staff Director
(II)
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00004 Fmt 5904 Sfmt 5904 F:\DOCS\39857.TXT DEBBIE
CONTENTS
OPENING STATEMENTS
Page
Hon. Andy Kim ........................................................................................................ 1
Hon. Kevin Hern ...................................................................................................... 3
WITNESSES
Mr. Jamie Yesnowitz, Principal, Grant Thornton, LLP, Washington, DC, testi-
fying on behalf of the American Institute of Certified Public Accountants
(AICPA) ................................................................................................................. 5
Mrs. Linda Lester, Vice President, K-Log, Inc., Zion, IL ..................................... 7
Mr. Kevin Mahoney, President and Founder, FindTape.com, North Bruns-
wick, NJ ................................................................................................................ 9
Mr. Brad Scott, Financial Director, Halstead Bead, Inc., Prescott, AZ .............. 10
APPENDIX
Prepared Statements:
Mr. Jamie Yesnowitz, Principal, Grant Thornton, LLP, Washington, DC,
testifying on behalf of the American Institute of Certified Public Ac-
countants (AICPA) ........................................................................................ 24
Mrs. Linda Lester, Vice President, K-Log, Inc., Zion, IL .............................. 37
Mr. Kevin Mahoney, President and Founder, FindTape.com, North
Brunswick, NJ ............................................................................................... 54
Mr. Brad Scott, Financial Director, Halstead Bead, Inc., Prescott, AZ ....... 115
Questions for the Record:
None.
Answers for the Record:
None.
Additional Material for the Record:
Statement of Matthew Behnke, President of Orthotic Shop Inc. ................. 146
Letter from Engine ........................................................................................... 149
Statement of Jason Chow, President of Chowren Toys LLC ........................ 151
Halstead Bead, Inc. .......................................................................................... 154
Mommy Makeup ............................................................................................... 158
National Auctioneers Association (NAA) ........................................................ 163
Statement of Kurt Frome, President, Roelz Frome, Inc. ............................... 182
Statement of Dean Sweberg, Managing Member of BBD Sales LLC .......... 183
Sovos Compliance LLC ..................................................................................... 185
U.S. Toy Company ............................................................................................ 189
Rio Grande, Inc. ................................................................................................ 190
Buyer’s Point ..................................................................................................... 191
Statement of Chris Holt, CEO Campman ...................................................... 193
Philadelphia Media Exchange ......................................................................... 195
Steiner Strategic Inc. ....................................................................................... 199
Statement of Wendy Kelly, Owner & Sole Operator of Kellyww ................. 202
Statement of Helen Kinson, Small Business Owner ..................................... 204
Etsy .................................................................................................................... 206
MO Vender Tax Aqua Design Appendix ......................................................... 208
Nina Designs ..................................................................................................... 258
Brann & Isaacson Attorneys and Counselors at Law ................................... 259
American Catalog Mailers Association (ACMA) ............................................ 261
Aqua Design High Performance Apparel ........................................................ 275
Bikes, Trikes and Quads .................................................................................. 279
Catching Clouds ................................................................................................ 281
Jenson Online Inc. ............................................................................................ 319
Statement of Joyce Latimer, Majority Member, SML Marketing LLC ........ 323
(III)
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00005 Fmt 5904 Sfmt 0486 F:\DOCS\39857.TXT DEBBIE
IV
Page
Additional Material for the Record—Continued
Hanalei Beauty Company ................................................................................ 335
Darn Good Yarn ................................................................................................ 337
Drone Speed LLC ............................................................................................. 339
Flashback Limited ............................................................................................ 341
CQC Boutique, LLC ......................................................................................... 347
Bedford Camera & Video ................................................................................. 352
Quick Ship Electronics ..................................................................................... 353
Crazy Dog T-Shirts ........................................................................................... 355
US-Mattress.com .............................................................................................. 357
MCR Medical .................................................................................................... 359
MacKinney Systems ......................................................................................... 360
National Conference of State Legislatures (NCSL) ....................................... 362
Fiona MA, CPA, State Board of Equalization ................................................ 364
Letter to Gov. Newsom from Fiona MA, CPA ................................................ 366
Marketplace Facilitators Letter to US Committee on Small Business ........ 371
MBW Northwest Incorporated ........................................................................ 373
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00006 Fmt 5904 Sfmt 0486 F:\DOCS\39857.TXT DEBBIE
SOUTH DAKOTA V. WAYFAIR, INC.: ONLINE
SALES TAXES AND THEIR IMPACT ON MAIN
STREET
TUESDAY, MARCH 3, 2020
HOUSE OF REPRESENTATIVES,
COMMITTEE ON SMALL BUSINESS,
SUBCOMMITTEE ON ECONOMIC GROWTH,
TAX, AND CAPITAL ACCESS,
Washington, DC.
The Subcommittee met, pursuant to call, at 10:05 a.m., in Room
2360, Rayburn House Office Building. Hon. Andy Kim [chairman of
the Committee] presiding.
Present: Representatives Kim, Davids, Schneider, Delgado, Hern,
and Stauber.
Chairman KIM. Good morning. The Subcommittee will come to
order.
I thank everyone for joining us this morning. I want to especially
thank the witnesses for being here today.
America’s small businesses are a catalyst for creating employ-
ment opportunities and driving growth in the U.S. economy. That
is because the 30 million small firms in the U.S. represent over 99
percent of all employers and support nearly 56 million jobs. That
is why we need to be enacting policies that help small businesses
deliver the products, services, jobs, innovation, and income that
Americans rely on.
One way for Congress to support small businesses is through
well-conceived and targeted tax policy. In my short time in Con-
gress and on this Committee, I have heard that small firms need
tax policy that is simple and certain along with policies that level
the playing field and create opportunities not just for Wall Street,
but for Main Streets across the country to thrive.
The Federal government plays an important role in the setting
tax policy, and I have seen firsthand back home now the change
in the SALT deductions has negatively impacted homeowners in
my district in New Jersey. However, tax laws enacted by states
and local jurisdictions also have an impact on small businesses, es-
pecially as economy becomes more interconnected.
New Jersey has a fairly simple sales tax system. The state
charges a uniform state sales tax of 6.625 percent, and we do not
have local sales taxes. Other states choose to do things differently.
Texas, for example, has 1,594 sales tax jurisdictions. Nationwide,
according to the Tax Foundation, there are 10,769 state and local
tax jurisdictions.
(1)
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00007 Fmt 6633 Sfmt 6633 F:\DOCS\39857.TXT DEBBIE
2
This is a critically important issue for small businesses selling
their goods and services online and for millions of others that are
engaging in interstate commerce. In the U.S. Supreme Court’s
landmark 2018 decision in South Dakota v. Wayfair, the Court de-
termined that the states could collect sales taxes from out-of-state
sellers. The decision overruled a 51-year-old precedent which estab-
lished that states could only collect sales taxes from businesses
that had brick-and-mortar locations in the state.
Even the businesses that sell on Amazon, which collects and re-
mits state sales taxes for small businesses, do not collect local sales
taxes, leaving small businesses to collect and remit local taxes in
thousands of jurisdictions across the country.
While sales taxes are an important source of revenue for the
state and local governments to build roads, maintain parks, and
pay teachers, police officers, and firefighters. But small business
owners should not be the collection arm for thousands of taxing ju-
risdictions. Small businesses simply do not have the time and the
resources to do so.
Let’s also be clear, this is not a tax avoidance issue. Small busi-
ness owners want to follow the law, but they need clear rules of
the road. The landscape post-Wayfair is that millions of small busi-
nesses are unfairly faced with overwhelming and expensive compli-
ance burdens. These burdens unfairly limit the ability of small
business owners to offer their products and services across state
lines.
I have heard from numerous companies in my own district about
the heavy financial burdens that they faced in the aftermath of the
Wayfair decision. One company I would like to highlight today is
the International Products Corporation, a small company that
manufactures precision cleaners and assembly lubricants in Bur-
lington, New Jersey. William Herbert, the CFO of the company
who has submitted written testimony for today’s hearing, has spent
thousands of dollars just to account for the many different tax ju-
risdictions within which they sell their products. Not only this, but
he has had to personally spend a couple days each month calcu-
lating and filing the returns in each state. Despite the significant
cost his company incurred for compliance, they ultimately paid only
$958 in total taxes to other jurisdictions last year. It seems down-
right unfair to put such burdens on our small businesses.
That is why today’s hearing is so important. This the first hear-
ing in Congress to solely focus on the small business impacts of the
Wayfair decision. We need to shed light on the problems that the
Wayfair decision has created for small businesses and explore some
actions that Congress can take to bring much needed relief. It
should be possible for state and local governments to collect the
revenue that pay for the public services we rely on without impos-
ing excessive compliance costs on small businesses.
It is my hope that this hearing will allow the voices of small
business owners to be heard. I also hope that this hearing will
serve as a springboard for members of Congress to work together
to solve this issue together. This is not just an issue in my state
but is an issue for all small business owners across the country.
I would now like to yield to Ranking Member Hern for his open-
ing statement.
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00008 Fmt 6633 Sfmt 6633 F:\DOCS\39857.TXT DEBBIE
3
Mr. HERN. Thank you, Mr. Chairman. Thank the witnesses for
being here today.
As a small business owner for the last 35 years, and 17 years on
bank boards, small community banks, 13 years as McDonald’s
Leadership Team representing over 3,500 franchisees that pay
multiple taxes in multiple jurisdictions. Even in my own organiza-
tion, 23 restaurants, 23 different communities, multiple tax issues
from city to state to county and the feds, and all the different
things that go on, it is a challenge.
Five years on the Systems Economic Team, I got to see this first-
hand, the impact; 5 years on the McDonald’s Tax Policy Team; and
many years on the McDonald’s Insurance Company Board. So, I am
in sort of a unique position to be on this Committee, and the Rank-
ing Member to know what happens to small business.
Again, multiple businesses across multiple jurisdictions, it is al-
ways a challenge for the small businessmen and women who are
trying to put their ideas to work, find capital, and create jobs and
put Americans to work.
The Chairman and I work well together to ensure small busi-
nesses operate in an economic and tax environment that allow
them to grow and expand and create jobs. Beyond my background
though, I am also a firm believer in our 10th Amendment. The
Constitution says the states can do it better than we can in Wash-
ington, D.C., and so I think it is also that we find that right bal-
ance to have a vitally important, thriving democracy.
This hearing will combine many of these elements together. With
the explosive growth of the Internet in this country, small busi-
nesses are building the next great product and creating the next
great service in ways that prior generations have never imagined.
Being connected to the Web has also introduced novel ways to
reach new customers. And while catalogue companies started to
chip away at proximity barriers, the Internet and ecommerce sites
have completely leveled any roadblocks. With new customers in
new locations, the question of taxes has become instrumental not
only for businesses but also states across the country. For years,
sales tax jurisdiction questions were answered by U.S. Supreme
Court cases, including Bella Hess v. Illinois in 1967, and Quill v.
North Dakota in 1992. These cases which focused on companies’
physical presence were the long-held standards for decades.
As ecommerce grew and matured, sales tax jurisdictional ques-
tions became even more instrumental.
At today’s hearing, we are going to be discussing the impact of
the Supreme Court’s most recent decision, South Dakota v.
Wayfair. Specifically, we are going to be hearing how the Wayfair
decision has impacted and infected small businesses across this
country. Our Nation’s smallest firms create nearly 70 percent of
new private sector jobs in America. Small businesses,
entrepeneurs, and startups are transforming neighborhoods and
communities from my state of Oklahoma to Minnesota and beyond.
And while driving the country’s economic engine forward, these
small businesses often operate with limited staff and resources.
This hearing will explore how these job creators have reacted to
the duly rights of states to enact sales tax requirements for remote
sellers after the Wayfair decision.
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00009 Fmt 6633 Sfmt 6633 F:\DOCS\39857.TXT DEBBIE
4
Again, I want to thank each of you for being here today to join
us in this conversation. And as I mentioned earlier, we know that
you have limited staff, so we appreciate you for taking your time
to be here today to talk to us about this very important issue. Your
thoughts and comments on this matter and all matters within our
economy are instrumental.
And with that, Mr. Chairman, I yield back.
Chairman KIM. Thank you. Thank you, Mr. Hern.
I always have to say, it is been great being able to do this in a
partnership with the Ranking Member, having the opportunity for
us to work together across the aisle. Very much committed together
on just trying to do what we can to help small businesses cut
through some of the bureaucracy and the red tape and the difficul-
ties that they have had while pursuing a level of just fairness
across the board. And that is exactly what he just said in his state-
ment. You know, what we are trying to figure out here is that right
balance, that right fairness. And I am glad to be able to continue
to work on that together with you.
I just wanted to take a second here. If other Committee members
have an opening statement prepared, we would ask that they be
submitted for the record.
I would like to just take a minute to explain the timing rules.
Each witness gets 5 minutes to testify and the members get 5 min-
utes for questioning. There is a lighting system to assist you right
in front of you. The green light comes on when you begin, a yellow
light comes on when you have 1 minute remaining, and a red light
comes on when you are out of time. And we ask that you stay with-
in that timeframe to the best of your abilities.
I would now like to just introduce our witnesses here.
Our first witness, Mr. Jamie Yesnowitz. Mr. Yesnowitz is a prin-
cipal at Grant Thornton, and also serves as the state and local tax
practice and national tax office leader. He is a recognized leader in
the state corporate income and sales tax legislation and policy,
state tax conformity to Federal tax provisions and state corporate
income tax apportionment rules. He holds an LLM in Taxation and
a JD from the University of Miami School of Law.
Welcome. Thanks for coming.
Our second witness is Ms. Linda Lester. And I would like to yield
to my colleague, Representative Schneider, for this introduction.
Mr. SCHNEIDER. Thank you, Chairman. And I want to welcome
all the witnesses. I am grateful you are here to share your stories.
It is my great privilege and pleasure to introduce our next wit-
ness, Ms. Linda Lester, who lives in my district. Ms. Lester is the
vice president of K-Log, a family owns business in Zion, Illinois,
that distributes quality, affordable, commercial furniture across the
country. I am proud that K-Log and its 30 employees call Zion
home. She holds a BA from the University of Illinois, Urbana-
Champaign, and has worked at K-log for the last 10 years. She has
been an invaluable resource for my office, in particular in under-
standing the impact of the Wayfair decision that it has on real day-
to-day businesses in our community and beyond.
Linda, thank you for joining us today.
Chairman KIM. Great. Thank you.
Welcome, Ms. Lester.
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00010 Fmt 6633 Sfmt 6633 F:\DOCS\39857.TXT DEBBIE
5
Our third witness today is Mr. Kevin Mahoney. Mr. Mahoney is
the founder and president of Findtape.com. Findtape.com is an
ecommerce business that sells tape, glue, adhesives, and dis-
pensers, located in North Brunswick, New Jersey. Mr. Mahoney
holds an M.S. in Information Systems from NYU Stern School of
Business and a B.S. in Finance from Penn State. So welcome, Mr.
Mahoney.
I would now like to yield to our Ranking Member, Mr. Hern, to
introduce our final witness.
Mr. HERN. And our final witness is Brad Scott. Mr. Scott is the
financial director of Halstead Bead, Inc., a jewelry component
wholesale company located in Prescott, Arizona. With 30 employ-
ees, Halstead Bead is a second-generation, family-owned small
business that has been in operation since the early 1970s. With
nearly 20 years of service at Halstead Bead, Mr. Scott directs the
company’s accounting operation and all tax matters. You are a
busy man.
Mr. Scott, we appreciate you taking the time away from your
business, and thanks for coming today to talk to us.
Chairman KIM. Yeah. Thank you so much. It is a real honor to
have all of you here, and it means a lot that you came here to
share your experience, your knowledge, and expertise with us.
With that, why don’t we jump right in.
Mr. Yesnowitz, you are recognized for 5 minutes. Over to you.
STATEMENTS OF JAMIE YESNOWITZ, PRINCIPAL, GRANT
THORNTON, LLP; LINDA LESTER, VICE PRESIDENT, K-LOG,
INC.; KEVIN MAHONEY, PRESIDENT AND FOUNDER,
FINDTAPE.COM; BRAD SCOTT, FINANCIAL DIRECTOR,
HALSTEAD BEAD, INC.
STATEMENT OF JAMIE YESNOWITZ
Mr. YESNOWITZ. Thank you, Chairman Kim, Ranking Member
Hern, and members of the Subcommittee. Thank you for the oppor-
tunity to testify on behalf of the AICPA.
In 2018, the Supreme Court expanded the states’ right to require
out-of-state sellers, commonly referred to as ‘‘remote sellers,’’ to col-
lect and remit sales tax by modifying the longstanding nexus test.
With this ruling, the Court endorsed a South Dakota statute re-
quiring remote sellers to register, collect and remit sales tax if they
meet at least one of two economic thresholds—either gross revenue
from sales delivered into the state over $100,000, or engaging in at
least 200 transactions involving items delivered into the state.
So how have the states responded? As a whole, they responded
quickly but not consistently. About half of the states adopted the
same economic thresholds as South Dakota. The other half adopted
variations, such as different sales thresholds or requiring that both
the transaction and sales thresholds are met. In at least one state,
the rules apply once the first sale is made to an in-state customer.
There is also a lack of uniformity in determining how and when
the economic thresholds apply. For example, some states count only
taxable sales while others use gross sales. So how does this impact
small businesses?
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00011 Fmt 6633 Sfmt 6633 F:\DOCS\39857.TXT DEBBIE
6
Businesses that traditionally maintained a physical footprint in
just one or two states now must consider whether their sales to
customers in a national marketplace subject them to the newer
rules. Nexus standards, threshold calculations, rate determina-
tions, and filing compliance are only some of the burdens on remote
businesses, and especially small businesses that do not have the re-
sources, revenue, or time to accurately comply with the various
rules across the Nation.
There are also situations where businesses have to register even
when their sales are tax exempt and file zero-dollar tax returns. In
that case, a business spends time complying with the law even
though the state will not get any additional revenue. Similar prob-
lems arise when states use a threshold based on the number of
transactions. For example, a business selling a product valued at
$10 to 200 customers with an 8 percent sales tax must collect a
grand total of $160. The compliance cost clearly exceeds this
amount.
Taken as a whole, there are often prohibitive costs attached to
ensuring that the compliance is performed correctly. If left un-
checked, the lack of uniformity in which the states have reacted
could impair small business growth, result in a loss in productivity,
and hamper their accountants’ ability to efficiently and effectively
serve them.
So how can we help small businesses? If Congress decides to ad-
dress these small business issues, we have a few suggestions. To
start, small businesses need more consistency between sales and
income tax nexus rules. Businesses are faced with a challenge
when it comes to the question of nexus. Are they subject to sales
tax, income tax, or both? The answer in many cases is unclear.
While it is impossible to completely align all sales and income
tax rules, it is possible for Congress to address the minimum
standards for which these rules apply. A natural starting point is
the standard established by the Multistate Tax Commission [the
MTC] back in 2002. It provides a safe harbor to determine if busi-
nesses are subject to business activity taxes. However, it is time to
modernize the approach since the MTC has not changed the
amounts for almost 20 years.
We recommend a uniform three-part test. If you exceed one part,
you have nexus in the state. First, for sales, there should be one
dollar threshold applicable for all of the states. The threshold
should apply to taxable sales for the sales tax and gross sales for
the income tax. The second part, for property located in the state,
we would suggest a $100,000 threshold for sales and income tax.
And finally, the third part, for payroll, we also suggest a $100,000
threshold.
There are several approaches to determining what is the right
dollar threshold for sales. Some states use the $500,000 amount
from the 2002 MTC standard. However, if inflation is taken into
account, that amount would be roughly $750,000. Finally, a $1 mil-
lion threshold would ensure that more small businesses are covered
under a safe harbor.
I don’t have time to get into all of our other suggestions, but I
want to note one area of growing concern. Small businesses selling
both directly and through a marketplace facilitator must deal with
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00012 Fmt 6633 Sfmt 6633 F:\DOCS\39857.TXT DEBBIE
7
even more complicated and inconsistent rules. In order to simplify
compliance and avoid situations in which double collection of sales
tax may occur, businesses need consistent and clear definitions, in-
cluding what constitutes a marketplace facilitator.
Thank you for the opportunity to testify, and I am happy to an-
swer any questions.
Chairman KIM. Great, thank you.
Well, why do we not get through all the witnesses first.
So, Ms. Lester, over to you for 5 minutes.
STATEMENT OF LINDA LESTER
Ms. LESTER. Good morning Chairman Kim, Ranking Member
Hern, and distinguished members of the Subcommittee and staff.
Thank you for inviting me to testify here today.
My name is Linda Lester and I am the vice president of K-Log,
a family-owned small business with 30 employees in Zion, Illinois.
Our company sells furniture primarily to public agencies, the ma-
jority of which are tax exempt.
Let me say right from the start, I am not opposed to collecting
and remitting sales taxes in all states. My struggle is with the cha-
otic manner in which remote sales tax has been mandated, as well
as the expense and time, money, and energy these mandates have
imposed.
I am here today as someone who has actually gone through the
process of registering for nationwide sales tax collection to try to
convey to you just how difficult it really is. It has taken us a year
to comply and register in 42 states, even though the majority of our
sales are tax exempt. I estimate that we have spent well over 1,500
hours so far at the cost of $75,000.
I have heard many times that there is a streamline process with
free software available to handle this. I am here to tell you that
it is not streamlined, and it is not free. First of all, only 24 states
have joined the Streamlined Sales Tax Coalition where uniform
standards have been set. The biggest states did not join because
they are too complex and could not meet the requirements.
Secondly, while the streamlined states might pay for the filing
fees, they do not pay for the cost of tying the software into our sys-
tems, exemption certification collection, training our staff, nor rec-
onciling data. All of these expenses are much higher than the min-
iscule filing fees paid by the states.
Here is the bottom line. If compliance were as easy as just imple-
menting free software, I would not be here today. If it were easy,
Illinois would have far more than only 5,000 or so remote sellers
currently collecting and remitting to the Illinois Department of
Revenue. Let that sink in. Out of the 30 million businesses in the
U.S., only 5,000 have registered as a remote seller in Illinois. I did
a FOIA request for that one. That tells me that there are a lot of
businesses nationwide struggling to comply.
I know very small businesses in compliance. Some are still un-
aware, and when I discuss it they look at me like I am crazy or
just plain wrong, while others are trying to comply and failing mis-
erably. The majority it seems are hoping that they can keep under
the radar and wait it out until the Federal government steps in
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00013 Fmt 6633 Sfmt 6633 F:\DOCS\39857.TXT DEBBIE
8
and comes up with a comprehensive solution because this simply
cannot be the way things will be from now on.
I fear that when all the states start notifying businesses that
they owe thousands of dollars for taxes on past sales that they
never collected in the first place, companies will start shutting
down and jobs will be lost, all because of a tax due that they did
not even know about in the first place. This is already happening
to Fulfilled by Amazon sellers.
I am here today to ask for your help in bringing order to the
marketplace, but I am not the only one asking. The state legisla-
tures of Arizona and New Hampshire have both passed resolutions
asking the Federal government to help with this. When I first
spoke to congressional staffers about this in October of 2018, I felt
like the canary in the coal mine trying to warn of impending doom.
While people listened sympathetically, the universal support that
I had hoped for just was not there. But it is now.
We need a simple, straightforward system that will not impose
an undue burden on businesses leading to increased compliance
and thus, increased revenue to the states. Any proposed solution
for a remote sales tax collection must include one rate per state,
a single filing point for all states, time to implement free of pen-
alties, and a comprehensive program to educate businesses and
consumers of the change.
I have some ideas on how to make this happen, and I am hoping
that now is the time to bring everyone to the table to start working
on sensible solutions to this complex problem.
There is far more to this than I can cover in just 5 minutes, but
I am going to give you just a few of the complexities while time
permits.
Colorado sales tax form is over 2,000 pages long and is filed
monthly. We had to compose a sales tax exemption booklet that is
248 pages long that has all the exemption certificates from all of
the states. Connecticut has 43 different tax exemption certificates,
so we have to look up on every transaction which one applies to
this specific customer and make sure we got the right one.
While Alabama collects local sales tax for its counties and cities,
a remote seller is required to register for accounts with the state,
plus four different private collection agencies and over 100 self-ad-
ministered counties and cities.
And now, when I thought I was finally compliant, having reg-
istered in the 42 states where we have nexus, I am starting to real-
ize that we have to address a franchise tax in Texas, a gross re-
ceipts tax in Ohio, an income tax in Pennsylvania, and I do not
know how many other tax obligations the states are demanding. I
am asking, no, begging you, to please work with me and the others
here to pass legislation that will fix this before more companies go
out of business and people lose their jobs. Thank you.
Chairman KIM. Thank you.
I appreciate your testimony there, and it helps me. I was won-
dering what those binders were about, so it is good to see in per-
son. I was not sure if it was a revised testimony or something.
Ms. LESTER. I mailed them. I did not bring them on the plane.
Chairman KIM. Well, thank you for bringing those in.
Mr. Mahoney, over to you for 5 minutes.
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00014 Fmt 6633 Sfmt 6633 F:\DOCS\39857.TXT DEBBIE
9
STATEMENT OF KEVIN MAHONEY
Mr. MAHONEY. Good morning. My name is Kevin Mahoney and
I want to start off by saying what an honor it is to be given this
opportunity to testify at today’s hearing.
I am the president and founder of Findtape.com, a specialty re-
tailer founded in 2004. Including myself, we have eight full-time
employees and are based out of Montgomery Township, New Jer-
sey. Our company sells tape, glue, and dispensers throughout the
U.S., and we currently ship to over 50 countries worldwide. Besides
our website, we also sell on marketplaces, such as Amazon,
Walmart, eBay, and Newegg.
After the Wayfair decision, many felt compliance for small busi-
nesses like mine would be made relatively easy by using software
to handle this new burden or by selling through a marketplace like
Amazon.
I am here to tell you that my experience has been anything but
easy. In reference to selling on marketplaces, we are currently un-
dergoing an audit by the State of Washington. The state’s claim is
that because Amazon transshipped our products between their own
interstate warehouses, the transshipping gave us physical nexus,
even though we never shipped anything directly into an Amazon
fulfillment center in the state.
Washington State retroactively claimed sales taxes from the
prior 5 years going back to 2013. Back in 2013, FindTape was only
a two-person company who never shipped direct into one of Ama-
zon’s Washington fulfillment centers, but they still came after us.
If you look at Washington State’s own law regarding consignees, it
fits Amazon’s FBA’s (Fulfilled by Amazon) program to a tee. Ama-
zon solely controls the entire buying experience, yet Washington
State is claiming we meet the old school definition of quill or phys-
ical nexus even though we did not transfer the goods or make the
sale ourselves.
This has been going on for over a year, and we have not received
back our final assessment. Since their sales tax rate can be as high
as 10.4 percent in some localities, the assessment will most likely
be in the tens of thousands of dollars. Washington State has now
even created a remote seller relief program, which we signed up for
because they say they will waive penalties and interest. This pro-
gram must have been created because there is a plethora of other
small businesses like ours that they are retroactively going after.
If we get assessed the full amount, we may have to lay off some
personnel, unfortunately.
Many states now have marketplace facilitator laws in place
which require marketplaces such as Amazon to collect and remit
sales taxes directly to the state. However, the economic nexus laws
do not provide any clarity if companies like mine are able to use
a separate threshold for our direct orders; rather, they get lumped
in with the orders that marketplaces are facilitating tax collection
on. And from a volume perspective, Amazon currently makes up
about 90 percent of the orders we get.
FindTape sells adhesive tape, not high-end jewelry or electronics.
When we sell 200 of our best-selling item on the Amazon market-
place, we make roughly $140 in profit. Because of the 90/10 split
between Amazon and our website, those additional 20
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00015 Fmt 6633 Sfmt 6633 F:\DOCS\39857.TXT DEBBIE
10
Findtape.com transactions would have brought in an extra 28 dol-
lars in profit. Therefore, for a total of $169 in profit, we have now
hit the economic nexus threshold of 200 transactions and would be
required to file in the state.
Just to be clear, we are not underestimating our transaction
numbers. If we look at all nonmarketplace orders in 2019, we had
15 transactions in Wyoming, 21 in South Dakota, and 35 in West
Virginia. We use the services of a company called TaxJar to cal-
culate our sales taxes owed and to file and remit them to the state.
We pay them just over $2,100 per year to get access to these serv-
ices. Primarily, the service allows us to request rates on which of
the 10,000-plus taxing jurisdictions the customer is shipping into.
We also pay TaxJar $20 per state filing they make for us. So, if
we are in a month where we have to file all 30 returns, since
Wayfair we are now currently registered and collecting taxes in 30
dates, that additional cost for the month is $600. While those costs
are an issue, the bigger challenge is the time it takes me to rec-
oncile the filings, plus I have to go through the daily correspond-
ence of sales tax related letters we receive from the states. It is in-
credibly stressful to open up your mail and see a stack of letters
from a state you have no real presence in. This all typically takes
me 1 to 2 days per month.
As a small business owner, my scarcest resource is time. Even
if economic nexus thresholds are altered to something more reason-
able, at the end of the day they end up being irrelevant since states
like Washington and Massachusetts are going after Amazon FBA
sellers for having physical, not economic nexus. All states already
have the ability to enact marketplace facilitator laws which will
allow them to receive tax dollars for the majority of online owners
anyway.
Back in 2018, Amazon already had a 49 percent share of the U.S.
ecommerce market, and if you threw eBay and Walmart into the
mix, that would have gotten states up to a 60 percent share.
We opened our first brick-and-mortar store in 2019 in New Jer-
sey. I understand how hard it is to compete with the likes of Ama-
zon and Walmart, and it would not be fair for brick-and-mortar re-
tailers to have to collect sales tax while an online order company
would not. But when someone comes into my store, I do not have
to ask them which of the 10,000-plus tax jurisdictions they live in.
Plus, I get the benefit of police and fire protection, roads are
plowed and repaired, good schools exist to supply talented employ-
ees and so forth from the taxes I am paying. If the local portion
of the sales tax rate could be eliminated for online sellers, that
would greatly simplify things.
Thank you for your time, and I look forward to your questions.
Chairman KIM. Thank you for your testimony there.
Mr. Scott, we are going to turn to you now. You are recognized
for 5 minutes.
STATEMENT OF BRAD SCOTT
Mr. SCOTT. Chairman Kim, Ranking Member Hern, and mem-
bers of the Committee, thank you for inviting me to testify.
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00016 Fmt 6633 Sfmt 6633 F:\DOCS\39857.TXT DEBBIE
11
My name is Brad Scott, and I am the finance director at my
wife’s family-owned small business, Halstead Bead. My wife, Hil-
lary, is the president of the company.
To date, our small business has spent more than $183,000 to col-
lect less than $80,000 in sales tax. Breaking that down, we are
spending $2.31 for every dollar we collect. We have diverted more
than 3,800 hours away from our business operations to act as un-
paid surrogate staff to 30 departments of revenue where we are
currently filing. If we fail to deliver, the consequences are grave.
Halstead is a second generation, privately owned, small whole-
sale business that was started in the early ‘70s by my wife’s par-
ents. Over the years, their two-person side hustle has grown into
the team of 27 employees we have now. Today, 94 percent of our
sales originate from our website. We distribute raw materials and
supplies to silver jewelers around the world. Our clients include the
smallest microbusinesses selling through sites like Etsy, as well as
traditional brick-and-mortar jewelry retailers.
We have spent decades developing an independent website and
IT infrastructure to maintain full control over our business model.
We do not sell on any marketplace facilitator websites because we
are unwilling to pay their commissions or cede control of our oper-
ational independence. Prior to the Wayfair decision, we had no
sales tax software in place.
Through our experience, we see four key issues to address, which
I have detailed in my written testimony.
Registration and filing, which is the obvious hurdle; software re-
quirements, which are the misunderstood hurdle; exemption certifi-
cate management, which is the unknown and underestimated hur-
dle; and finally, the unprecedented liability and lack to due process.
The Wayfair decision is often described as a court case aimed at
major online retailers, but that is misleading. The majority of
states are using gross sales as their threshold metric. This encom-
passes all forms of businesses across state lines, not just Internet
retail activity. What’s more, in 2018, Wayfair, the defendant in the
case, reported approximately $6.8 billion in revenue. They are more
than 1,000 times bigger than us. A company like Wayfair has the
resources to staff a state and local tax department. We are trying
to navigate this new landscape with a single accountant. The ex-
pectation is that one person can bring a company into compliance
as effectively as an entire SALT department at a major corpora-
tion. I am that one person, and I can tell you it is not possible.
The sales tax solution that is so often discussed was and is not
free. There were substantial integration costs and there are month-
ly filing transactions for non-streamlined states. The software is
also inadequate. In 2019 alone, I received 36 notices from 12
streamlined states that the filings and/or remittances that our cer-
tified software provider is contracted to submit on our behalf were,
in fact, not submitted. It took months to get these addressed,
though some are still not fully resolved.
One cannot stress enough the anxiety caused by receiving one
notice from a Department of Revenue, let alone 36. One of those
notices from the State of Tennessee, was over $38.22 in penalties
and interest due to a failure to report by our software company.
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00017 Fmt 6633 Sfmt 6633 F:\DOCS\39857.TXT DEBBIE
12
In February, concurrent memorials passed through both the Ari-
zona House and Senate with unanimous approval. These memo-
rials are entitled ‘‘Urging the United States Congress to enact uni-
form national legislation for remote sellers to collect and remit
sales taxes.’’ We are grateful to our state’s elected officials for rec-
ognizing the challenges facing constituent small businesses and for
making this formal request for Federal intervention.
At Halstead, we have a successful, profitable small business. We
have prospered in our 47 years, but nothing has shaken us like
Wayfair. We have considered closing our doors because of the
stress and liability. We could literally lose everything.
We urgently need Federal intervention. In our opinion, there are
two suggestions that stand above the rest. First, due process is be-
yond our reach because of the Tax Anti-Injunction Act. Allow a
small business to use their home state’s court system or Federal
courts to fight assessments. And second, a single statewide remote
seller sales tax rate should be the standard. Penny parity causes
unnecessary complexity and burden. Our written statement in-
cludes additional recommendations.
We ask the Subcommittee to please elevate this issue to legisla-
tion for uniformity to relieve this tremendous burden on small
businesses.
Thank you, and I look forward to taking your questions.
Chairman KIM. Thank you, Mr. Scott.
Your testimony was very strong, and as you were talking about
having to even make that thought of having to close the doors be-
cause of this type of problem, that is exactly why we are here today
and trying to figure out what we can do to provide relief and con-
sistency to across the board.
I am going to start by just jumping in with a few questions here.
You know, most states have adopted that similar economic nexus
levels following the Wayfair decision where businesses reaching
certain revenue levels or numbers of transactions in a given state
are subject to tax collection by that state. Each of you have run
through that in terms of how it has affected you of other businesses
that you know.
I want to sort of establish sort of a baseline across the board, so
I would love to go across the panel here and just get your sort of
baseline assessment here.
Do you think that the most common standard of the $100,000 in
sales and $200,000 in transactions is a reasonable standard? And
if not, what do you think would be a reasonable threshold just so
that we have sort of clarity across all four of you?
Mr. Yesnowitz, why do we not start with you and then we will
move down the line.
Mr. YESNOWITZ. Sure. As noted in the testimony, regarding the
$100,000 and 200 transaction thresholds that were adopted by
South Dakota and adopted by about half the states, the AICPA
does not think that would be a sufficient level. The Multistate Tax
Commission set forth the $500,000 sales standard for factor pres-
ence nexus. I believe they use the $50,000 standard for payroll and
property. So, if you had a little bit of physical presence in the state,
that would be protected. I think with the new economy and over
the past 20 years, changes in the pricing and the like, we think
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00018 Fmt 6633 Sfmt 6633 F:\DOCS\39857.TXT DEBBIE
13
that from the perspective of sales, $500,000 might not be sufficient
to protect the small businesses out there. And so, we have sug-
gested as possibilities a $750,000 standard or $1 million standard
to cover even more small businesses and to increase the payroll
and property factor, or the payroll and property levels from $50,000
to $100,000 each.
Chairman KIM. Okay, great.
Ms. Lester, what are your thoughts on this?
Ms. LESTER. I have kind of a different approach to this in that
I think it is complicated and hard to do whether you are a $10 mil-
lion company or a $100 million company. We sell furniture, office
furniture and school furniture. We sell stuff like this here, as well
as cafeteria furniture in a school. So, we may have one transaction
of cafeteria furniture into Nebraska and it is a $40,000 sale. So, I
think it is kind of misleading to just go on numbers. We may have
two or three sales into one state, and we hit the nexus just because
of the nature of our transaction.
What I really think we need to do, as long as you are asking, is
make this simple enough that a nexus is irrelevant. If you have one
rate per state and one place to file, then anybody can do this. You
could do this with no nexus. Just as in now, I know that my own
Illinois rate is 7 percent. If I had a list that here is the 50 states
and here is the rates and you pay it here, you would not even have
to mess with a nexus. Everybody would know what to do.
But if I had to answer your question and I have to set a nexus
level, I would agree that $1 million sounds like the minimum it
should be. If you are going to go through all this, you have to have
a substantial amount of business into that state to make it worth-
while.
Chairman KIM. Okay.
Ms. LESTER. That would be my opinion.
Chairman KIM. Thank you for that.
Mr. Mahoney, where is your head on this?
Mr. MAHONEY. I think, number one, having a number of trans-
actions threshold should be eliminated. What primarily sells online
is inexpensive goods. I mean, we sell adhesive tape. That is not ex-
pensive. I am not going to make a lot of money selling 200. But
for us, economic nexus really is irrelevant because the states are
coming after us as an Amazon FBA seller for having physical
nexus.
I have had several conference calls with Washington State dur-
ing the audit, and I have asked them, I mean, in the Wayfair rul-
ing I think it mentioned having substantial nexus. And when I
bring that up they say, well, we are not coming after you for eco-
nomic nexus. Even if Amazon transshipped one item, that is now
giving you physical nexus in the state. So, for an Amazon FBA sell-
er, the economic nexus thresholds are not really relevant.
And if you look at Amazon’s 49 percent of U.S. ecommerce in
2018, and that number is just growing so there is a lot of Amazon
FBA sellers out there.
Chairman KIM. Mr. Scott, over to you.
Mr. SCOTT. Thank you.
So based on the transactional threshold, I think those should be
eliminated altogether. They make no sense based on small sales.
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00019 Fmt 6633 Sfmt 6633 F:\DOCS\39857.TXT DEBBIE
14
If you want to talk about a threshold, I think a national thresh-
old makes more sense than a state-by-state threshold. And going
by the Small Business Administration’s definition of what a retail
small business is, $30 million and less is a small business. So, if
you are going to set a threshold, I think that is the starting point
at the bare minimum. Or you could also use the threshold that
South Dakota used, which is $100,000, and if it is adjusted for
GDP across all the states amounts to closer to $40 million. So a
national exemption would make this simpler in the sense that in-
stead of having to comply with states piecemeal, you either have
to comply or you are under that threshold, period, in which case
you can focus on your business at hand.
Chairman KIM. Okay, great. We will likely have a couple rounds
here for questions here, but I want to give the Ranking Member
an opportunity.
So, Mr. Hern, over to you.
Mr. HERN. Thank you.
Mr. Yesnowitz, you talked about the marketplace facilitator legis-
lation. Could you walk us through how that works? I could ask Mr.
Mahoney, but let’s just go with you since you are on the tax side
here.
Mr. YESNOWITZ. Sure. With respect to marketplace facilitators,
they are operators of online malls. They are intermediaries to
transactions. They set up sellers and purchasers. So, they are not
a party to the transaction itself that is taking place, but they facili-
tate the transaction in one of several different ways.
The states decided after Wayfair (and Wayfair did not address
this fact pattern), but after Wayfair, the states acted with respect
to remote seller legislation and then with respect to marketplace
facilitators, they required that if they have a little bit of economic
presence in the jurisdiction, they were well placed enough to re-
quire the facilitator to collect and remit sales tax with respect to
that transaction.
Mr. HERN. So they are supposed to be the one that identifies all
these 10,000 different tax jurisdictions and collect the approrpite
tax and then remit those back. I think Mr. Mahoney, you had men-
tioned it was like a 90/10, 9 percent, or how do they get paid?
Mr. MAHONEY. For our website, 90 percent of the volume of or-
ders are on Amazon, and then just 10 percent on our website.
Mr. HERN. Okay. So how do these facilitators get paid for doing
that service? Or is it just part of their monthly marketplace fee?
Mr. MAHONEY. There are a variety of different ways in which
they get paid. There are some fee exchanges and the like. I think
that from the perspective of the marketplace facilitators that end
up being—some of them are very large, sure, the Amazons of the
world. But with respect to some they are small businesses and they
may feel like they are doing a little bit of facilitation in some juris-
dictions. And to be required to comply with all the states once they
reach a minimal economic threshold, a couple of activities in each
of these states seems somewhat onerous.
Mr. HERN. Mr. Mahoney, you had mentioned 90/10. So, I think
what you were trying to describe or did describe earlier was the 90
percent that were sold through your marketplace would be charged
at a gross rate currently because of the taxes applied locally
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00020 Fmt 6633 Sfmt 6633 F:\DOCS\39857.TXT DEBBIE
15
through the marketplace. And the 10 percent would be some other
price based on trying to determine what those taxes would be. So,
somebody buying form two different jurisdictions would say why is
this same product more expensive here at a retail price or at a
sticker price, if you will, because the tax is included and the other
side it is not. Is that——
Mr. MAHONEY. I mean, for us, if it is selling on the Amazon
Marketplace and it is a marketplace facilitated state, it is pretty
easy. TaxJar just automatically imports those orders and remits, so
we do not really have to worry about it. For us, for the 10 percent
of orders that come on the Findtape.com website, I use that TaxJar
service and it tells me, you know, which of the 10,000 jurisdictions
I am shipping into and it gives me the tax breakdown. And then
we remotely send that order to TaxJar and at the end of the month
they file it.
Mr. HERN. Okay.
Mr. MAHONEY. So.
Mr. HERN. Mr. Scott, given that small businesses have limited
resources and limited staff, knowing the rules of the road is para-
mount to growing, expanding, and creating jobs. Do you believe
that small businesses are aware of the rules and requirements on
collecting and remitting sales tax? And what resources are avail-
able to help you better know?
Mr. SCOTT. Well, anecdotally speaking, in all of the companies
that we have had conversations with surrounding sales tax, unless
they are in this room currently, they are usually not aware. Or
they are aware but they are also aware of how expensive it is to
comply and the fact that they are so far behind the starting date
at this point in time they are unwilling to put themselves out there
because when you do register, if you are delayed at your registra-
tion point you typically get a call from that Department of Revenue
expecting an immediate audit.
Mr. HERN. You say people, if they know, and they are learning
as they go along here, they just say catch me if you can, basically?
Mr. SCOTT. I do not think it is catch me if you can so much as
this is a hurdle that there is no way for us to realistically get over.
And so what we are hoping for is that Congress will act and force
some degree of uniformity and protections for small businesses so
that when we do come forward in good faith, because most of us
do, that we are not going to be punished just because of a court
decision that happened 2 years ago that we were not made aware
of until, you know, potentially 3 hours ago.
Mr. HERN. Yeah. Yeah, so it does create the problem we have
here with the Federal government interacting with states; right? I
mean, I get it. Obviously, as you heard me say in my introduction,
the Federal government trying to identify single tax per state, I
mean, I get the ease of that. But that would be a statewide sales
tax; right? But every jurisdiction inside the state also has a par-
ticular county tax or city tax that also has to be collected somehow
or the other if it is sold within a metropolitan area.
I will get that on the second round because I have some more
clarity, I want to talk to you about, Mr. Lester.
Chairman KIM. Yeah, we want to make sure we kind of dive into
this.
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00021 Fmt 6633 Sfmt 6633 F:\DOCS\39857.TXT DEBBIE
16
So, Mr. Mahoney, I wanted to return to you. In your opening
statement you were talking about sort of the issues with nexus
that you had with Washington State, and I thought that was very
powerful just to hear how difficult that was.
I wanted to ask you if you have had any other states contact you
about additional nexus? I am just curious. Beyond Washington
State in terms of the difficulties that were provided. Have you ex-
perienced that elsewhere as well?
Mr. MAHONEY. Yeah. Right now, the only audit we have had
is Washington State. We have received letters. Arizona has sent us
a letter. We actually received a letter from California, but we reg-
istered back in 2009, so they just had our account number wrong,
so they thought we were not paying but we have been paying for
a while.
But we tried to, in good faith, as soon as Wayfair got announced,
we went from collecting in five states to 30 pretty much right at
the end of 2018. So, I feel like the companies that tried to do the
right thing and immediately collected, we have this burden on us.
And there are a lot of companies that just are not aware of the
competition. And they are not incurring the same costs we are.
Chairman KIM. Mr. Scott, I wanted to just get your thoughts on
this in terms of, you know, states that have contacted you about
nexus. Just want to get your feel for this.
Mr. SCOTT. So the decision came down on June 21st almost 2
years ago, and to date we have received a single notification from
the State of Pennsylvania that we may have an obligation to collect
and remit sales tax. The other 44 states and District of Columbia,
nobody has ever reached out to us. I should say 43 because we al-
ready knew about Arizona.
What is more, we also are now aware that we have a topline tax
requirement with some of these states. California has a franchise
tax and Washington has a business and occupation tax. We volun-
tarily disclosed that we were unaware of those and were assessed
back taxes in those regards as well.
Chairman KIM. Okay. I wanted to turn over to Ms. Lester. I
wanted to ask you a question just from your own experiences. What
states are the easiest to comply with and why? And what states
would say are the most difficult to comply with and why? I just
want to sort of set—so it is the boundaries, left and right limits
here.
Ms. LESTER. It is a great question. It is hard to keep them all
straight, so I am going to refer to my notes here.
Chairman KIM. Sure.
Ms. LESTER. Indiana, Kentucky, Michigan, New Jersey, and
Rhode Island get high marks in my opinion because—but I think
it is more important to focus on why they get high marks. And that
is because they have one rate per state, and it is an EZ filing form.
The other two that I would say that we found to be helpful are
Texas and Louisiana. Both take a unique approach in that they are
complicated states; however, they allow remote sellers the option of
doing one rate per state. When you register with them you get your
choice. You can either do one rate per state or you can follow all
the jurisdictions for remote seller. Louisiana calls it——
Chairman KIM. That was Texas and which?
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00022 Fmt 6633 Sfmt 6633 F:\DOCS\39857.TXT DEBBIE
17
Ms. LESTER. Louisiana. Louisiana calls it their direct marketer
form.
So, if I was selling a type of a product that had a lower tax rate
than the statewide they presented, then I could maybe choose to
do that for my customers, or I can choose the other one. So that
was a good approach in my opinion.
As far as the worst, Colorado. That is one month’s form. They re-
quire you to submit it electronically for obvious reasons. I printed
it just to bring it here today to show you. All the rest of the states
are right here. This is all the rest of the states we do.
I would say that Colorado’s problem is that they have 682 taxing
jurisdictions that they collect on behalf of the local jurisdictions,
and there are three pages for each one of those jurisdictions, which
is why the book is so big. We had actually four sales into the state
that month and had to produce a document this big.
My concern with this is that our software generates the report,
but I obviously cannot read it to see if it is accurate. I have to sign
off on a report that I can proof the total, but I cannot go through
it.
Some of the other complicated states are all the ones that have
lots of taxing jurisdictions. Alabama requires us to file two forms,
an Alabama state form and a local tax form. And on the local tax
form, the first time we did not know we have to file it, we had zero
taxes due and they assessed us a $100 penalty for not filing our
zero tax report because we did not know we had to do it. And then
the following month, once we did do it, we realized we had to get
tax ID numbers. For about half of the local jurisdictions you had
to contact someone else to get your Tax ID Number because they
did not use the state one. It is insane what they do.
The bottom line is one rate per state with an EZ filing form is
not too much to ask because a lot of states already do it.
Chairman KIM. Thanks for that.
I still have a few more questions, but I am going to turn it over
to the rnaking member for his second round.
Mr. HERN. Actually, I am just going to continue on. Went down
the same line of thinking.
I appreciate what you said about having no thresholds because
my experience is that anytime any government applies a threshold
to anything there is always gaming of that system. And sometimes
that is not good. Curtailing growth of a small business, when we
talked about—we could talk about the Affordable Care Act on small
business not going beyond 49 employees. The list goes on. It is a
truth that is out there. Anytime you put a threshold, people will
figure out how to stay under that. Even going to the extent of cre-
ating another business with dissimilar ownership so that you can
stay under that. It is just a fact. I mean, that is what
businesspeople do. They figure how to make the amount of money
out of current law. You tell me the rules, I will play the game.
So, I appreciate you saying that. That is a true entrepreneur that
understands. I understand what you are saying about the one rate.
I do want to ask you that because I appreciate you pointing out
that two states do that, or maybe more, but you specifically called
out Texas and Louisiana. Why do you think they do that, have one
rate? You have the ability, the option, the choice as a
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00023 Fmt 6633 Sfmt 6633 F:\DOCS\39857.TXT DEBBIE
18
businessperson doing business in their state to either go through
and fill out all the forms or just do one rate. And I am assuming
the one rate is encapsulating all the rates, the highest rates, and
they distribute those to the local municipalities where you do busi-
ness in those states. Why do you think those two states do that?
Ms. LESTER. I do not know. I did not ask them. But my as-
sumption would be because that is an easy way for people to then
comply. I will say that Mr. Scott and I met in November at a simi-
lar forum and I asked him what state do you think is the most
complicated and he said one of his most complicated was Louisiana.
And I said, oh, really? Did you know they have the direct marketer
form that you can pay one rate? And he said, no, I did not know
that. So even when it is simple, not everybody knows that the op-
tions are available. We had several states where we filed and had
to redo it a different way. So, I can only assume it is because they
feel that, well, I will get more people to comply.
Mr. HERN. Or encourage you to do more business there because
it is easier to do business there possibly.
Ms. LESTER. Possibly. In our case, we mail catalogues. We sell
office and school furniture, and we mail catalogues all over the
country. So, we do business in every state. We actually cater to
governments that we mail to the Department of Revenue in every
state which is one of the other reasons why we have now signed
up in every state.
Mr. HERN. Just for the record, and I think someone said it, just
for the record, nobody that is in business is opposed to collecting
tax and remitting tax to the proper jurisdiction. It is just the com-
plications that are required to do that and the risk that you have
if you miss. Like you said, just not even—and trust me, I have been
where you have been, and it is extraordinarily frustrating. I did not
owe you anything but now I do.
Ms. LESTER. Well, and we had six states where we did not meet
the $100,000 threshold, but some of the states say, as soon as you
meet the threshold, that month you have to register. Or there are
a few states that I am sorry I cannot name which one says on the
day you meet threshold you have to register. So, we thought, am
I going to have to like every week say did I meet the threshold yet?
Did I meet it yet? Did I meet it yet? So, to me if I was going to
do 36 states, I might as well do 42 and be done with registering
everywhere.
Mr. HERN. Not that I am proposing this but would an acceptable
solution be that encouraging states to have a single tax that encap-
sulates all of their tax, deal with this franchise tax, income tax,
whatever it may be, sales tax, a singular rate, do you think that
would be acceptable to online retailers?
Ms. LESTER. I would not go there. I do not feel that, you know,
in Texas, for example, has said that we have to pay a franchise tax,
and it is probably going to cost us $2,000 to $3,000 this year. We
have no employees there. No assets there. No nothing there other
than our customers happen to reside there. And yet we would be
subject to all these other taxes. I am also concerned that once we
get one tax, they are going to throw other ones in, too.
I personally believe that sales tax makes sense. The customer is
there. It is a sale. That is the only thing that is happening there
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00024 Fmt 6633 Sfmt 6633 F:\DOCS\39857.TXT DEBBIE
19
in that state. So yes, I will collect the sales tax on your behalf, and
I will send it. But having to answer to all of these other taxes does
not make sense.
Mr. HERN. Mr. Chairman, I yield back.
Chairman KIM. I wanted to turn to Mr. Yesnowitz for a question
here.
Even though this hearing has been focused in on sales taxes, are
there now income tax implications as well from states that small
firms must worry about? I just want to get your thoughts on this.
Mr. YESNOWITZ. There definitely are because of the fact that
when Wayfair came out, Wayfair required all these new businesses
to come into the state for sales tax purposes. It does not prevent
the states from reaching back and looking to see, well, have you
done stuff in the state in the past that would require you to pay
corporate income taxes? And so, we have already seen some activ-
ity in that area where states are now more interested in the in-
come tax. There are a few jurisdictions in 2019 that decided to
throw on an economic nexus threshold for purposes of their cor-
porate income taxes. And so that is definitely a level of concern. In
addition, with respect to looking at financial statements, you have
to make adjustments with respect to corporate income tax liability,
things that have changed. And so when a company recognizes that
they were in a state, and from an economic nexus threshold, they
were in a state and it did not matter that they did not have phys-
ical presence, companies have to reevaluate that from a financial
statement perspective. And so, the accounting firms have certainly
had to deal with that.
Chairman KIM. Okay.
Mr. MAHONEY. We paid over $5,000 in income tax in California
just last year. Last time we shipped direct into a California Ama-
zon warehouse was probably over 3 years ago. So, we pay income
tax. I have no presence in that state. I cannot vote in that state.
I mean, taxation without representation. You know, I am paying
income tax in a state I do not even have any presence there, so.
Chairman KIM. Yeah. No, thanks for that.
Actually, I would like to stay with you, Mr. Mahoney. When I
was going through your testimony, the written testimony, you men-
tioned the marketplace facilitator laws. Are the states that have
marketplace facilitator laws in place easier to sell in, file with, or
pay taxes in?
Mr. MAHONEY. You know, for us it does not really make a dif-
ference. I mean, one thing, when we collect sales tax, the other
thing I do not think we mentioned, you know, it is a credit card
fee. So, I am losing 2-1/2 to 3-1/2 percent if it is an Amex card right
off the bat on that. One thing I like with marketplace facilitated,
when Amazon is collecting, at least I am not losing the credit card
swipe fee. But at the end of the day it does not really make that
much of a difference for us.
Chairman KIM. And Mr. Scott, I wanted to turn to you. What
resources have you used to work your way through this? And par-
ticularly, was the Small Business Administration helpful at all?
Just trying to get a sense of what tools are and what approaches
you have taken.
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00025 Fmt 6633 Sfmt 6633 F:\DOCS\39857.TXT DEBBIE
20
Mr. SCOTT. Well, I mentioned earlier in my testimony that we
have spent more than 3,800 hours on this, and a lot of that has
been time by my wife, the president of the company, and myself,
plowing through different departments of revenues websites trying
to understand the legalese, the threshold terminology, and the re-
quirements that have been put on us in the last year and a half.
So, are there any resources? Not really. There are places where
you can get little bits of information here and there that span more
than a few states, but by and large, most of our research had been
from the Department of Revenue websites themselves primarily be-
cause the information changes with such regularity that looking at
online resources, collecting all of that information in our opinion is
not really fully trustworthy. And maybe that is not fair. But in a
sense, you know, just being overly concerned about our own liabil-
ity we prefer to see these things for ourselves. With the Small
Business Administration, this is not really something that is under
their purview as of right now. The Office of Advocacy has been
helping us to a degree in the sense that they are letting us know
that, yeah, things are moving forward in slow methodical ways, but
they are an office of resources financially or of statistics, but not
with assistance as far as determining what we can do with the
states.
Chairman KIM. Mr. Mahoney, just going off of what you were
talking about earlier, I just wanted to kind of clarify. Does Amazon
collect the local tax? And if not, what has been your experience
through that process?
Mr. MAHONEY. Amazon typically collects both the state and
local. Sometimes there are issues. I think Illinois this last month
there was an Amazon—actually, I have received several emails
from Amazon. They did not calculate, and Linda may know more
about what changed in Illinois, but they only set the state taxes
in and did not calculate on the local. So, there was a lot of back
and forth. And then they sent a correction email out. So, there was
some complexity. But typically, they collect all sales tax taxes for
us.
Chairman KIM. Ms. Lester, did you have anything you wanted
to add to this?
Ms. LESTER. We do not sell on Amazon, so this is not first-hand
experience. But 2 weeks ago, my accountant called me and said, I
have a customer who sells on Amazon, and since you know so much
about this maybe you can help. Apparently, what Amazon does is
it collects the 6.25 percent state tax but does not collect the local
tax in Illinois, which is another, for where I am, another .75 per-
cent. And so, my accountant was asking how do we collect this
extra money? Amazon did not collect it from the customer, but we
know we still owe it. I do not even know how to report it on the
form. Amazon has sent a notice to its sellers in Illinois telling them
we do not do the local tax. Sorry, we will get to it. At some point,
hopefully, we will have it solved.
I actually reached out to the tax authority at the Illinois Cham-
ber of Commerce asking them what to do and he said, that is not
right. And he contacted Amazon directly and came back and said,
yeah, you are right. They do not do it and we are stuck right now,
so.
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00026 Fmt 6633 Sfmt 6633 F:\DOCS\39857.TXT DEBBIE
21
Chairman KIM. Thanks for sharing that.
I want to turn it back to the Ranking Member.
Mr. HERN. Yeah, just a question for you, Ms. Lester. And just
as a point of clarity, I was asking counsel this, and we are not sure
of the answer. You have a book there. I think you said it was 182
taxing jurisdictions in Colorado.
Ms. LESTER. Actually, it is 682.
Mr. HERN. Six hundred eighty two.
Ms. LESTER. Times three pages each.
Mr. HERN. So a question for you, and you may not know this
answer, but it is something that we need to find out the answer
to. If you are an online retailer in Denver and you sell across the
state, inside the state, so you are required as that retailer in the
state to collect the state, the city, each one of those jurisdictions
and remit to each jurisdiction within the state?
Ms. LESTER. Well, 682 of them you just file with the state and
the state does it on their behalf. Okay? However, the form is three
pages for each jurisdiction. So, it is only one point. But I will say
there is an additional 97 jurisdictions that the state does not do on
their behalf. And you would have to register with each one of those
individually and do them. Denver is one of them, as well as Colo-
rado Springs. So, for those I have to check every month and say
did we hit Denver yet, a nexus? We are kind of up in the air to
be honest with you what we are supposed to do with the other 97
jurisdictions. It is bad enough dealing with this one.
Mr. HERN. But it does create a little bit of an awkward scenario
for us as far as authority from the Federal government going inside
of a state and telling a state how they are to collect their own taxes
in their own state when the business resides in the state. And this
is sort of the predicament we are in. That is why we are here col-
lecting a lot of information from you all and to get a better under-
standing of how this process is going to have to work going for-
ward.
Mr. Scott, I can see you wanted to say something so badly.
Mr. SCOTT. Yes, sir. Thank you.
Colorado is a special state. We are a wholesaler predominantly.
Mr. HERN. Some would agree with you.
Mr. SCOTT. Right. Right.
We are a wholesaler predominantly, and there are reasons why
we do collect retail sales tax on some transactions. But if you look
at the nature of our sales, we are a wholesaler. And Colorado is
a state where we have prohibited any sales into the state that are
not wholesale. Meaning, we have to have an exemption certificate
for them. And we are also limiting sales into that state, too stay
below a threshold because we do not want to run afoul of their De-
partment of Revenue.
Mr. HERN. Okay.
Mr. Miller, did you want to say something to that or no? Okay.
Mr. MILLER. We find with Colorado.
Mr. Yesnowitz, what are your thoughts on that being in the tax
business?
Mr. YESNOWITZ. Well, I mean, with regard to states and local-
ities and the Federal government being able to intervene, the Fed-
eral government does have the ability to do that. They have acted
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00027 Fmt 6633 Sfmt 6633 F:\DOCS\39857.TXT DEBBIE
22
in the area of corporate income tax, for example. Sixty years ago,
you had Public Law 86-272, and that protects companies that do
limited solicitation activities within a state from taxation if they
are selling tangible personal property and take the orders outside
the state. So, the government has acted in the past. So, under-
standing that there is a sensitivity to trying to deal with a state
issue here, I think Congress does have that power. With respect to
this particular issue, I think that Congress needs to be concerned
about the fact that in the 18 months since Wayfair, you have all
these states acting independently and in a nonuniform manner,
and it makes it really difficult for small businesses like these to be
able to handle all that in such a short period of time and that is
why the AICPA is recommending some level of uniformity here.
Mr. HERN. So is AICPA also recognizing of states’ ability to call
back use tax when individuals go to states that have a lower use
tax and buy high-ticket items and take them back to their state
and then the state goes after these particular individuals from cir-
cumventing use laws?
Mr. YESNOWITZ. Well, the AICPA wants compliance.
Mr. HERN. Okay.
Mr. YESNOWITZ. They understand the fact that the use tax is
an important component of the sales tax.
Mr. HERN. Okay.
Mr. YESNOWITZ. I know that we had a recent experience where
my daughter wanted to buy something online, in the state of Mary-
land. The company was based out in California and she really
wanted it and bought it. And no sales tax applied to it. I am like,
you realize what I have to do now. And she said, what do we have
to do? I said, we have got to pay the use tax on this, clearly. I am
not going to get myself into trouble over it. So, she did not get it
[the use tax concept], but a lot of people do not. And understand-
ably, the states really do need to do more in the area of use tax
enforcement. They put line items on the income tax returns for
folks to self-report. But yes, there is a tax gap there. I understand
that.
Mr. HERN. Any thoughts? I mean, I know this is not your area
because you are more policy than you are in the competitive world.
Do you see any states that would take this as an opportunity, espe-
cially higher populated states that would take this as an oppor-
tunity to make this more compliant easy, if you will, so that online
retailers would do business in their state more regularly than else-
where?
Mr. YESNOWITZ. I am not sure from a competitiveness stand-
point that one state would go over another. I know that some of
the states have applied these new economic thresholds using a
market threshold. For example, South Dakota is a much smaller
market than California. So, California is putting in a higher stand-
ard than South Dakota. So, we are seeing some of that. The advan-
tage there is, well, for small businesses, it is much easier to trip
a threshold in a big market state if everything were the same.
From the simplicity standpoint it is a little bit difficult when you
have got to deal with all these different numbers and using a mar-
ket amount for that might be problematic.
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00028 Fmt 6633 Sfmt 6633 F:\DOCS\39857.TXT DEBBIE
23
Mr. HERN. Mr. Chairman, I thank all the witnesses that have
obviously done a lot of work in this area. It is near and dear. That
is where you get your best thinking, from the people who are actu-
ally experiencing the issues. I appreciate your time, being away
from your businesses, and from what you do, and thanks for giving
us suggestions of what to look at here so we can work on this as
we go forward.
And Mr. Chairman, I would yield back my time except I have
none. So, thank you.
Chairman KIM. I just want to echo what the Ranking Member
just said. As we have gone through a number of different hearings
over the time to just continue to have small business owners and
experts and others take time to be able to come to our humble
chamber here and talk to us about what it is that we can try to
do to help small businesses. It really means a lot. The stories you
have told are not just compelling in terms of the facts, in terms of
the numbers and the information, the recommendations, but we
can really see in each of you just the frustrations that you have
had, but the real passion that you bring to try to get this done, to
try to have something that is going to be fair for small businesses.
So, I just wanted to say thank you for taking time out of your busy
schedules to come.
As we started out at the beginning of this hearing, we said that
one way for Congress to support small businesses is through well-
conceived and targeted tax policy. As we heard today, small busi-
nesses need tax policy that is simple and certain, not everchanging.
Small businesses also need tax policy that levels the playing field
and creates opportunities for their businesses to thrive.
Following the Wayfair decision, many small businesses are facing
compliance costs and burdens that are hurting their businesses’
abilities to succeed. This calls upon Congress to try to take steps
to think through this thoughtfully and try to find some solutions
to these problems that you have presented to us today.
I look forward to working with my members on both sides of the
aisle to solve these issues for America’s small businesses.
With that I would ask unanimous consent that members have 5
legislative days to submit statements and supporting materials for
the record.
Without objection, so ordered.
And if there is no further business to come before the Sub-
committee, we are adjourned. Thank you so much.
[Whereupon, at 11:14 a.m., the subcommittee was adjourned.]
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00029 Fmt 6633 Sfmt 6633 F:\DOCS\39857.TXT DEBBIE
24
APPENDIX
SBD026 with DISTILLER Insert offset folio 24 here 39857.001
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00030 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
25
SBD026 with DISTILLER Insert offset folio 25 here 39857.002
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00031 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
26
SBD026 with DISTILLER Insert offset folio 26 here 39857.003
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00032 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
27
SBD026 with DISTILLER Insert offset folio 27 here 39857.004
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00033 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
28
SBD026 with DISTILLER Insert offset folio 28 here 39857.005
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00034 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
29
SBD026 with DISTILLER Insert offset folio 29 here 39857.006
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00035 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
30
SBD026 with DISTILLER Insert offset folio 30 here 39857.007
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00036 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
31
SBD026 with DISTILLER Insert offset folio 31 here 39857.008
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00037 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
32
SBD026 with DISTILLER Insert offset folio 32 here 39857.009
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00038 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
33
SBD026 with DISTILLER Insert offset folio 33 here 39857.010
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00039 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
34
SBD026 with DISTILLER Insert offset folio 34 here 39857.011
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00040 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
35
SBD026 with DISTILLER Insert offset folio 35 here 39857.012
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00041 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
36
SBD026 with DISTILLER Insert offset folio 36 here 39857.013
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00042 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
37
SBD026 with DISTILLER Insert offset folio 37 here 39857.014
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00043 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
38
SBD026 with DISTILLER Insert offset folio 38 here 39857.015
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00044 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
39
SBD026 with DISTILLER Insert offset folio 39 here 39857.016
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00045 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
40
SBD026 with DISTILLER Insert offset folio 40 here 39857.017
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00046 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
41
SBD026 with DISTILLER Insert offset folio 41 here 39857.018
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00047 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
42
SBD026 with DISTILLER Insert offset folio 42 here 39857.019
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00048 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
43
SBD026 with DISTILLER Insert offset folio 43 here 39857.020
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00049 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
44
SBD026 with DISTILLER Insert offset folio 44 here 39857.021
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00050 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
45
SBD026 with DISTILLER Insert offset folio 45 here 39857.022
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00051 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
46
SBD026 with DISTILLER Insert offset folio 46 here 39857.023
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00052 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
47
SBD026 with DISTILLER Insert offset folio 47 here 39857.024
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00053 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
48
SBD026 with DISTILLER Insert offset folio 48 here 39857.025
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00054 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
49
SBD026 with DISTILLER Insert offset folio 49 here 39857.026
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00055 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
50
SBD026 with DISTILLER Insert offset folio 50 here 39857.027
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00056 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
51
SBD026 with DISTILLER Insert offset folio 51 here 39857.028
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00057 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
52
SBD026 with DISTILLER Insert offset folio 52 here 39857.029
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00058 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
53
SBD026 with DISTILLER Insert offset folio 53 here 39857.030
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00059 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
54
SBD026 with DISTILLER Insert offset folio 54 here 39857.031
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00060 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
55
SBD026 with DISTILLER Insert offset folio 55 here 39857.032
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00061 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
56
SBD026 with DISTILLER Insert offset folio 56 here 39857.033
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00062 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
57
SBD026 with DISTILLER Insert offset folio 57 here 39857.034
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00063 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
58
SBD026 with DISTILLER Insert offset folio 58 here 39857.035
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00064 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
59
SBD026 with DISTILLER Insert offset folio 59 here 39857.036
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00065 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
60
SBD026 with DISTILLER Insert offset folio 60 here 39857.037
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00066 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
61
SBD026 with DISTILLER Insert offset folio 61 here 39857.038
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00067 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
62
SBD026 with DISTILLER Insert offset folio 62 here 39857.039
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00068 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
63
SBD026 with DISTILLER Insert offset folio 63 here 39857.040
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00069 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
64
SBD026 with DISTILLER Insert offset folio 64 here 39857.041
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00070 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
65
SBD026 with DISTILLER Insert offset folio 65 here 39857.042
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00071 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
66
SBD026 with DISTILLER Insert offset folio 66 here 39857.043
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00072 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
67
SBD026 with DISTILLER Insert offset folio 67 here 39857.044
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00073 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
68
SBD026 with DISTILLER Insert offset folio 68 here 39857.045
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00074 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
69
SBD026 with DISTILLER Insert offset folio 69 here 39857.046
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00075 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
70
SBD026 with DISTILLER Insert offset folio 70 here 39857.047
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00076 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
71
SBD026 with DISTILLER Insert offset folio 71 here 39857.048
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00077 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
72
SBD026 with DISTILLER Insert offset folio 72 here 39857.049
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00078 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
73
SBD026 with DISTILLER Insert offset folio 73 here 39857.050
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00079 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
74
SBD026 with DISTILLER Insert offset folio 74 here 39857.051
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00080 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
75
SBD026 with DISTILLER Insert offset folio 75 here 39857.052
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00081 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
76
SBD026 with DISTILLER Insert offset folio 76 here 39857.053
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00082 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
77
SBD026 with DISTILLER Insert offset folio 77 here 39857.054
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00083 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
78
SBD026 with DISTILLER Insert offset folio 78 here 39857.055
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00084 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
79
SBD026 with DISTILLER Insert offset folio 79 here 39857.056
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00085 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
80
SBD026 with DISTILLER Insert offset folio 80 here 39857.057
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00086 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
81
SBD026 with DISTILLER Insert offset folio 81 here 39857.058
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00087 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
82
SBD026 with DISTILLER Insert offset folio 82 here 39857.059
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00088 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
83
SBD026 with DISTILLER Insert offset folio 83 here 39857.060
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00089 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
84
SBD026 with DISTILLER Insert offset folio 84 here 39857.061
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00090 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
85
SBD026 with DISTILLER Insert offset folio 85 here 39857.062
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00091 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
86
SBD026 with DISTILLER Insert offset folio 86 here 39857.063
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00092 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
87
SBD026 with DISTILLER Insert offset folio 87 here 39857.064
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00093 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
88
SBD026 with DISTILLER Insert offset folio 88 here 39857.065
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00094 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
89
SBD026 with DISTILLER Insert offset folio 89 here 39857.066
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00095 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
90
SBD026 with DISTILLER Insert offset folio 90 here 39857.067
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00096 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
91
SBD026 with DISTILLER Insert offset folio 91 here 39857.068
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00097 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
92
SBD026 with DISTILLER Insert offset folio 92 here 39857.069
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00098 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
93
SBD026 with DISTILLER Insert offset folio 93 here 39857.070
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00099 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
94
SBD026 with DISTILLER Insert offset folio 94 here 39857.071
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00100 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
95
SBD026 with DISTILLER Insert offset folio 95 here 39857.072
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00101 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
96
SBD026 with DISTILLER Insert offset folio 96 here 39857.073
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00102 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
97
SBD026 with DISTILLER Insert offset folio 97 here 39857.074
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00103 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
98
SBD026 with DISTILLER Insert offset folio 98 here 39857.075
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00104 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
99
SBD026 with DISTILLER Insert offset folio 99 here 39857.076
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00105 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
100
Insert offset folio 100 here 39857.077
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00106 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
101
Insert offset folio 101 here 39857.078
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00107 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
102
Insert offset folio 102 here 39857.079
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00108 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
103
Insert offset folio 103 here 39857.080
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00109 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
104
Insert offset folio 104 here 39857.081
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00110 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
105
Insert offset folio 105 here 39857.082
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00111 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
106
Insert offset folio 106 here 39857.083
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00112 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
107
Insert offset folio 107 here 39857.084
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00113 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
108
Insert offset folio 108 here 39857.085
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00114 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
109
Insert offset folio 109 here 39857.086
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00115 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
110
Insert offset folio 110 here 39857.087
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00116 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
111
Insert offset folio 111 here 39857.088
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00117 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
112
Insert offset folio 112 here 39857.089
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00118 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
113
Insert offset folio 113 here 39857.090
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00119 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
114
Insert offset folio 114 here 39857.091
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00120 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
115
Insert offset folio 115 here 39857.092
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00121 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
116
Insert offset folio 116 here 39857.093
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00122 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
117
Insert offset folio 117 here 39857.094
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00123 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
118
Insert offset folio 118 here 39857.095
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00124 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
119
Insert offset folio 119 here 39857.096
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00125 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
120
Insert offset folio 120 here 39857.097
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00126 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
121
Insert offset folio 121 here 39857.098
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00127 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
122
Insert offset folio 122 here 39857.099
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00128 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
123
Insert offset folio 123 here 39857.100
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00129 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
124
Insert offset folio 124 here 39857.101
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00130 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
125
Insert offset folio 125 here 39857.102
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00131 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
126
Insert offset folio 126 here 39857.103
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00132 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
127
Insert offset folio 127 here 39857.104
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00133 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
128
Insert offset folio 128 here 39857.105
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00134 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
129
Insert offset folio 129 here 39857.106
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00135 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
130
Insert offset folio 130 here 39857.107
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00136 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
131
Insert offset folio 131 here 39857.108
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00137 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
132
Insert offset folio 132 here 39857.109
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00138 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
133
Insert offset folio 133 here 39857.110
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00139 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
134
Insert offset folio 134 here 39857.111
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00140 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
135
Insert offset folio 135 here 39857.112
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00141 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
136
Insert offset folio 136 here 39857.113
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00142 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
137
Insert offset folio 137 here 39857.114
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00143 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
138
Insert offset folio 138 here 39857.115
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00144 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
139
Insert offset folio 139 here 39857.116
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00145 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
140
Insert offset folio 140 here 39857.117
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00146 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
141
Insert offset folio 141 here 39857.118
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00147 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
142
Insert offset folio 142 here 39857.119
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00148 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
143
Insert offset folio 143 here 39857.120
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00149 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
144
Insert offset folio 144 here 39857.121
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00150 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
145
Insert offset folio 145 here 39857.122
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00151 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
146
Insert offset folio 146 here 39857.123
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00152 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
147
Insert offset folio 147 here 39857.124
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00153 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
148
Insert offset folio 148 here 39857.125
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00154 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
149
Insert offset folio 149 here 39857.126
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00155 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
150
Insert offset folio 150 here 39857.127
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00156 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
151
Insert offset folio 151 here 39857.128
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00157 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
152
Insert offset folio 152 here 39857.129
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00158 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
153
Insert offset folio 153 here 39857.130
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00159 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
154
Insert offset folio 154 here 39857.131
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00160 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
155
Insert offset folio 155 here 39857.132
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00161 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
156
Insert offset folio 156 here 39857.133
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00162 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
157
Insert offset folio 157 here 39857.134
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00163 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
158
Insert offset folio 158 here 39857.135
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00164 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
159
Insert offset folio 159 here 39857.136
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00165 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
160
Insert offset folio 160 here 39857.137
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00166 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
161
Insert offset folio 161 here 39857.138
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00167 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
162
Insert offset folio 162 here 39857.139
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00168 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
163
Insert offset folio 163 here 39857.140
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00169 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
164
Insert offset folio 164 here 39857.141
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00170 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
165
Insert offset folio 165 here 39857.142
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00171 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
166
Insert offset folio 166 here 39857.143
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00172 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
167
Insert offset folio 167 here 39857.144
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00173 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
168
Insert offset folio 168 here 39857.145
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00174 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
169
Insert offset folio 169 here 39857.146
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00175 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
170
Insert offset folio 170 here 39857.147
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00176 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
171
Insert offset folio 171 here 39857.148
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00177 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
172
Insert offset folio 172 here 39857.149
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00178 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
173
Insert offset folio 173 here 39857.150
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00179 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
174
Insert offset folio 174 here 39857.151
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00180 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
175
Insert offset folio 175 here 39857.152
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00181 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
176
Insert offset folio 176 here 39857.153
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00182 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
177
Insert offset folio 177 here 39857.154
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00183 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
178
Insert offset folio 178 here 39857.155
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00184 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
179
Insert offset folio 179 here 39857.156
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00185 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
180
Insert offset folio 180 here 39857.157
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00186 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
181
Insert offset folio 181 here 39857.158
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00187 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
182
Insert offset folio 182 here 39857.159
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00188 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
183
Insert offset folio 183 here 39857.160
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00189 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
184
Insert offset folio 184 here 39857.161
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00190 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
185
Insert offset folio 185 here 39857.162
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00191 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
186
Insert offset folio 186 here 39857.163
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00192 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
187
Insert offset folio 187 here 39857.164
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00193 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
188
Insert offset folio 188 here 39857.165
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00194 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
189
Insert offset folio 189 here 39857.166
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00195 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
190
Insert offset folio 190 here 39857.167
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00196 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
191
Insert offset folio 191 here 39857.168
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00197 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
192
Insert offset folio 192 here 39857.169
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00198 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
193
Insert offset folio 193 here 39857.170
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00199 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
194
Insert offset folio 194 here 39857.171
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00200 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
195
Insert offset folio 195 here 39857.172
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00201 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
196
Insert offset folio 196 here 39857.173
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00202 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
197
Insert offset folio 197 here 39857.174
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00203 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
198
Insert offset folio 198 here 39857.175
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00204 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
199
Insert offset folio 199 here 39857.176
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00205 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
200
Insert offset folio 200 here 39857.177
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00206 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
201
Insert offset folio 201 here 39857.178
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00207 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
202
Insert offset folio 202 here 39857.179
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00208 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
203
Insert offset folio 203 here 39857.180
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00209 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
204
Insert offset folio 204 here 39857.181
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00210 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
205
Insert offset folio 205 here 39857.182
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00211 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
206
Insert offset folio 206 here 39857.183
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00212 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
207
Insert offset folio 207 here 39857.184
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00213 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
208
Insert offset folio 208 here 39857.185
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00214 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
209
Insert offset folio 209 here 39857.186
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00215 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
210
Insert offset folio 210 here 39857.187
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00216 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
211
Insert offset folio 211 here 39857.188
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00217 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
212
Insert offset folio 212 here 39857.189
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00218 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
213
Insert offset folio 213 here 39857.190
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00219 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
214
Insert offset folio 214 here 39857.191
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00220 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
215
Insert offset folio 215 here 39857.192
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00221 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
216
Insert offset folio 216 here 39857.193
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00222 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
217
Insert offset folio 217 here 39857.194
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00223 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
218
Insert offset folio 218 here 39857.195
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00224 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
219
Insert offset folio 219 here 39857.196
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00225 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
220
Insert offset folio 220 here 39857.197
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00226 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
221
Insert offset folio 221 here 39857.198
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00227 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
222
Insert offset folio 222 here 39857.199
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00228 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
223
Insert offset folio 223 here 39857.200
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00229 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
224
Insert offset folio 224 here 39857.201
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00230 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
225
Insert offset folio 225 here 39857.202
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00231 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
226
Insert offset folio 226 here 39857.203
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00232 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
227
Insert offset folio 227 here 39857.204
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00233 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
228
Insert offset folio 228 here 39857.205
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00234 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
229
Insert offset folio 229 here 39857.206
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00235 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
230
Insert offset folio 230 here 39857.207
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00236 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
231
Insert offset folio 231 here 39857.208
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00237 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
232
Insert offset folio 232 here 39857.209
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00238 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
233
Insert offset folio 233 here 39857.210
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00239 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
234
Insert offset folio 234 here 39857.211
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00240 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
235
Insert offset folio 235 here 39857.212
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00241 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
236
Insert offset folio 236 here 39857.213
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00242 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
237
Insert offset folio 237 here 39857.214
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00243 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
238
Insert offset folio 238 here 39857.215
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00244 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
239
Insert offset folio 239 here 39857.216
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00245 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
240
Insert offset folio 240 here 39857.217
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00246 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
241
Insert offset folio 241 here 39857.218
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00247 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
242
Insert offset folio 242 here 39857.219
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00248 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
243
Insert offset folio 243 here 39857.220
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00249 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
244
Insert offset folio 244 here 39857.221
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00250 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
245
Insert offset folio 245 here 39857.222
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00251 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
246
Insert offset folio 246 here 39857.223
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00252 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
247
Insert offset folio 247 here 39857.224
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00253 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
248
Insert offset folio 248 here 39857.225
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00254 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
249
Insert offset folio 249 here 39857.226
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00255 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
250
Insert offset folio 250 here 39857.227
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00256 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
251
Insert offset folio 251 here 39857.228
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00257 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
252
Insert offset folio 252 here 39857.229
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00258 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
253
Insert offset folio 253 here 39857.230
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00259 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
254
Insert offset folio 254 here 39857.231
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00260 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
255
Insert offset folio 255 here 39857.232
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00261 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
256
Insert offset folio 256 here 39857.233
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00262 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
257
Insert offset folio 257 here 39857.234
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00263 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
258
Insert offset folio 258 here 39857.235
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00264 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
259
Insert offset folio 259 here 39857.236
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00265 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
260
Insert offset folio 260 here 39857.237
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00266 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
261
Insert offset folio 261 here 39857.238
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00267 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
262
Insert offset folio 262 here 39857.239
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00268 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
263
Insert offset folio 263 here 39857.240
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00269 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
264
Insert offset folio 264 here 39857.241
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00270 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
265
Insert offset folio 265 here 39857.242
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00271 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
266
Insert offset folio 266 here 39857.243
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00272 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
267
Insert offset folio 267 here 39857.244
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00273 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
268
Insert offset folio 268 here 39857.245
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00274 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
269
Insert offset folio 269 here 39857.246
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00275 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
270
Insert offset folio 270 here 39857.247
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00276 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
271
Insert offset folio 271 here 39857.248
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00277 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
272
Insert offset folio 272 here 39857.249
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00278 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
273
Insert offset folio 273 here 39857.250
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00279 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
274
Insert offset folio 274 here 39857.251
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00280 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
275
Insert offset folio 275 here 39857.252
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00281 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
276
Insert offset folio 276 here 39857.253
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00282 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
277
Insert offset folio 277 here 39857.254
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00283 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
278
Insert offset folio 278 here 39857.255
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00284 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
279
Insert offset folio 279 here 39857.256
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00285 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
280
Insert offset folio 280 here 39857.257
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00286 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
281
Insert offset folio 281 here 39857.258
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00287 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
282
Insert offset folio 282 here 39857.259
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00288 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
283
Insert offset folio 283 here 39857.260
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00289 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
284
Insert offset folio 284 here 39857.261
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00290 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
285
Insert offset folio 285 here 39857.262
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00291 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
286
Insert offset folio 286 here 39857.263
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00292 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
287
Insert offset folio 287 here 39857.264
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00293 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
288
Insert offset folio 288 here 39857.265
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00294 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
289
Insert offset folio 289 here 39857.266
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00295 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
290
Insert offset folio 290 here 39857.267
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00296 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
291
Insert offset folio 291 here 39857.268
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00297 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
292
Insert offset folio 292 here 39857.269
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00298 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
293
Insert offset folio 293 here 39857.270
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00299 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
294
Insert offset folio 294 here 39857.271
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00300 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
295
Insert offset folio 295 here 39857.272
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00301 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
296
Insert offset folio 296 here 39857.273
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00302 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
297
Insert offset folio 297 here 39857.274
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00303 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
298
Insert offset folio 298 here 39857.275
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00304 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
299
Insert offset folio 299 here 39857.276
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00305 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
300
Insert offset folio 300 here 39857.277
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00306 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
301
Insert offset folio 301 here 39857.278
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00307 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
302
Insert offset folio 302 here 39857.279
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00308 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
303
Insert offset folio 303 here 39857.280
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00309 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
304
Insert offset folio 304 here 39857.281
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00310 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
305
Insert offset folio 305 here 39857.282
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00311 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
306
Insert offset folio 306 here 39857.283
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00312 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
307
Insert offset folio 307 here 39857.284
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00313 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
308
Insert offset folio 308 here 39857.285
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00314 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
309
Insert offset folio 309 here 39857.286
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00315 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
310
Insert offset folio 310 here 39857.287
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00316 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
311
Insert offset folio 311 here 39857.288
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00317 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
312
Insert offset folio 312 here 39857.289
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00318 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
313
Insert offset folio 313 here 39857.290
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00319 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
314
Insert offset folio 314 here 39857.291
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00320 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
315
Insert offset folio 315 here 39857.292
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00321 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
316
Insert offset folio 316 here 39857.293
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00322 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
317
Insert offset folio 317 here 39857.294
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00323 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
318
Insert offset folio 318 here 39857.295
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00324 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
319
Insert offset folio 319 here 39857.296
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00325 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
320
Insert offset folio 320 here 39857.297
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00326 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
321
Insert offset folio 321 here 39857.298
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00327 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
322
Insert offset folio 322 here 39857.299
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00328 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
323
Insert offset folio 323 here 39857.300
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00329 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
324
Insert offset folio 324 here 39857.301
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00330 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
325
Insert offset folio 325 here 39857.302
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00331 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
326
Insert offset folio 326 here 39857.303
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00332 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
327
Insert offset folio 327 here 39857.304
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00333 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
328
Insert offset folio 328 here 39857.305
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00334 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
329
Insert offset folio 329 here 39857.306
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00335 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
330
Insert offset folio 330 here 39857.307
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00336 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
331
Insert offset folio 331 here 39857.308
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00337 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
332
Insert offset folio 332 here 39857.309
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00338 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
333
Insert offset folio 333 here 39857.310
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00339 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
334
Insert offset folio 334 here 39857.311
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00340 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
335
Insert offset folio 335 here 39857.312
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00341 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
336
Insert offset folio 336 here 39857.313
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00342 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
337
Insert offset folio 337 here 39857.314
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00343 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
338
Insert offset folio 338 here 39857.315
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00344 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
339
Insert offset folio 339 here 39857.316
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00345 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
340
Insert offset folio 340 here 39857.317
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00346 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
341
Insert offset folio 341 here 39857.318
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00347 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
342
Insert offset folio 342 here 39857.319
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00348 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
343
Insert offset folio 343 here 39857.320
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00349 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
344
Insert offset folio 344 here 39857.321
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00350 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
345
Insert offset folio 345 here 39857.322
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00351 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
346
Insert offset folio 346 here 39857.323
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00352 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
347
Insert offset folio 347 here 39857.324
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00353 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
348
Insert offset folio 348 here 39857.325
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00354 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
349
Insert offset folio 349 here 39857.326
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00355 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
350
Insert offset folio 350 here 39857.327
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00356 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
351
Insert offset folio 351 here 39857.328
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00357 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
352
Insert offset folio 352 here 39857.329
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00358 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
353
Insert offset folio 353 here 39857.330
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00359 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
354
Insert offset folio 354 here 39857.331
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00360 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
355
Insert offset folio 355 here 39857.332
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00361 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
356
Insert offset folio 356 here 39857.333
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00362 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
357
Insert offset folio 357 here 39857.334
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00363 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
358
Insert offset folio 358 here 39857.335
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00364 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
359
Insert offset folio 359 here 39857.336
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00365 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
360
Insert offset folio 360 here 39857.337
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00366 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
361
Insert offset folio 361 here 39857.338
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00367 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
362
Insert offset folio 362 here 39857.339
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00368 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
363
Insert offset folio 363 here 39857.340
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00369 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
364
Insert offset folio 364 here 39857.341
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00370 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
365
Insert offset folio 365 here 39857.342
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00371 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
366
Insert offset folio 366 here 39857.343
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00372 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
367
Insert offset folio 367 here 39857.344
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00373 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
368
Insert offset folio 368 here 39857.345
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00374 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
369
Insert offset folio 369 here 39857.346
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00375 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
370
Insert offset folio 370 here 39857.347
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00376 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
371
Insert offset folio 371 here 39857.348
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00377 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
372
Insert offset folio 372 here 39857.349
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00378 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
373
Insert offset folio 373 here 39857.350
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00379 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
374
Insert offset folio 374 here 39857.351
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00380 Fmt 6602 Sfmt 6602 F:\DOCS\39857.TXT DEBBIE
375
Æ
Insert offset folio 375 here 39857.352
SBD026 with DISTILLER
VerDate Mar 15 2010 15:10 Nov 04, 2020 Jkt 000000 PO 00000 Frm 00381 Fmt 6602 Sfmt 6011 F:\DOCS\39857.TXT DEBBIE
File and source
- File
- CHRG-116hhrg39857.pdf
- Size
- 149,352,888 bytes
- SHA-256
- 0f348e162f95d80c17cf3580f3deb665be90b8d4b1b66288fad26c79d9eeb69c
- Our copy
- CHRG-116hhrg39857.pdf
- Original
- www.govinfo.gov