Addendum.

The July 2002 Tax Clinic item, "ERP Systems and Record Retention," at p. 442, stated on p. 444, in the paragraph entitled "Meeting the Requirements":

   The most widely used ERP system, SAP, does not provide a means to store
   files sequentially once removed from the live system (such as during
   archiving). A retention solution developed by the Americas SAP User's Group
   meets these requirements. It provides a means by which files can be copied
   from the live system, as long as the relevant transaction details are
   copied to secure sequential files that can then be reviewed during tax
   audits. Although this solution was designed to meet the basic
   record-retention requirements established in Rev. Rul. 71-20 and Rev. Proc.
   91-59 and further clarified in Rev. Proc. 98-25, taxpayer-specific
   customization may be necessary.

According to David E. Nelson, Product Manager for Taxation at SAP Labs, SAP is not an ERP system; it is the manufacturer of the R/3 ERP system. Although the act of archiving data within the R/3 system removes such data from direct online access, it can be accessed with the archiving R/3 system via included index-based access utilities. The archived data is not readily accessible by non-SAP systems.

SAP Development created a data retention tool (DART), released in April 1998 and developed using tax experts from the R/3 user community under the auspices of Americas' SAP User Group (ASUG). ASUG members provided necessary tax expertise, but no coding. DART helps R/3 users meet Rev. Proc. 98-25's requirements and is provided at no additional cost.

The R/3 user community was advised that DART's sample data extraction was not meant to include every data type a taxpayer might need to comply with Rev. Proc. 98-25. However, DART's utilities allow the extraction to be extended to include whatever R/3 data an individual taxpayer needs. The knowledge to implement "customer-specific customization" referred to above is available from SAP-sponsored classroom instruction or consultants. For more information, see www.sapinsideronline.com/searchspi/search.htm?page=article&key=20994.