24 Nigeria

Teresa Ter-Minassian
Published Date:
September 1997
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Michael Mered

Nigeria has a complex system of fiscal federalism that has undergone important changes since the country became independent in 1960. Several factors have played a key role in shaping Nigeria’s federal system. Nigeria is a large country both in terms of land area and population with considerable ethnic, religious, linguistic, and climatic diversity, all factors that favor decentralization. Petroleum production (all on or around the Niger delta) took off in the 1970s, and the country has changed from a poor agricultural economy into a relatively rich, oil-dominated one. The oil sector now accounts for some 27 percent of GDP, 98 percent of exports, and 75 percent of government revenue. The management of the geographically concentrated oil resources has always been the responsibility of the central (federal) government. The political system, entailing a delicate balance between diverse regional, ethnic, and religious interests, has undergone considerable changes since independence; Nigeria has witnessed periods of civilian and military rules and of civil war. While expenditure assignments have remained broadly unchanged over time, tax assignments and the revenue-sharing arrangements have always been a contentious issue between the federal government and the lower authorities.

The Structure of Government

Nigeria operates a federal system with three tiers—federal, state, and local governments (Table 1). The government sector consists of (1) the federal authority; (2) 30 state governments, which include 9 new states created in 1991; and (3) 589 local governments.1

Table 1.Nigeria: Intergovernmental Fiscal Relations1(In percent of GDP)
Federal government
Total revenue (retained)21.517.717.615.110.611.0
Federation Account revenue9.
Other oil revenue7.
Independent revenue20.
Federal Stabilization Account3.
Total expenditure24.524.417.233.019.414.7
Recurrent expenditure15.914.414.517.513.310.0
Capital expenditure and net lending4.
Supplementary and extrabudgetary outlays4.15.3−
Overall balance (deficit −)−2.9−6.70.4−17.9−8.8−3.7
States, local governments, and special funds
Total revenue13.712.512.410.78.37.2
Federation Account8.
Federal Stabilization Account3.
Independent and VAT revenue31.
Expenditure and net lending13.19.811.510.08.07.3
Net lending to federal government0.
Balance (deficit −)−0.1
Consolidated government
Federation Account25.723.022.618.612.510.3
Federal government8.
Other petroleum revenue7.
Independent revenue0.
State governments1.
Overall balance (deficit −)−2.3−4.11.3−17.2−8.5−3.8
Sources: Data provided by the Nigerian authorities; and IMF staff estimates.

Transactions are shown on a cash basis. Data for state and local governments are highly provisional and are based on limited budgetary information.

Excludes recoveries at source for debt obligations of state governments.

State governments only.

Excludes Nigerian National Petroleum Company’s dedicated oil revenues and cash calls.

Sources: Data provided by the Nigerian authorities; and IMF staff estimates.

Transactions are shown on a cash basis. Data for state and local governments are highly provisional and are based on limited budgetary information.

Excludes recoveries at source for debt obligations of state governments.

State governments only.

Excludes Nigerian National Petroleum Company’s dedicated oil revenues and cash calls.

Regional fiscal autonomy was increasingly strengthened before independence, when the colonial authorities decided that budgetary surpluses of the central administration should be transferred to regional governments. In response to the size and ethnic diversity of the country, the system evolved from a unitary to a quasi-federal state and then to a full-fledged federal system in 1954. Following independence, while the Constitution vested much of the legislative and executive authority in the center, political power became highly regionalized. This situation resulted in a stalemate, which led to the eventual collapse of the first republic in 1966 and a military takeover. The federal military government de-emphasized regional fiscal autonomy, weakening the power of the states by increasing their numbers from 4 to 30 by 1991. At the same time, the local governments began to play a more significant role in intergovernmental relations. Local fiscal autonomy was particularly strengthened when the federal authority, in 1976, decided to allocate to the local governments 10 percent of the Federation Account revenue,2 which was further increased to 20 percent in 1992. The state authorities, however, continue to have significant influence on the budgetary decisions of local governments.

Although all levels of government have their own independent sources of revenue, the funding of government expenditure comes to a large extent from federally collected revenues, which are accumulated in the Federation Account at the Central Bank of Nigeria and then distributed among the different branches of government according to statutory shares (statutory transfers).

Current Intergovernmental Fiscal Arrangements

Expenditure Assignment

The assignment of expenditure to the different levels of government has not changed significantly since independence, except for some instances when the federal government took over some state or local function for a variety of reasons. Nevertheless, the existing disparities in natural endowments and in the level of economic development among the states have tended to create cost and quality differentials in the delivery of public services, requiring either a restructuring of expenditure assignments or increased transfers of resources to the states.

For example, in 1976 the federal authority, for the purpose of ensuring minimum standards and in an effort to reduce costs, began to finance all education outlays.

At present, the federal government is responsible for economic planning and for policies aimed at redistribution and stabilization. In addition, the maintenance of law and order, foreign affairs, defense, the regulation of international and interstate trade and, as mentioned above, education are the responsibilities of the federal authorities. State governments are charged with the supply of public services in the areas of health, agriculture, and public utilities, while services such as town planning, sanitation, and veterinary care are within the domain of local governments (Table 2).

Table 2.Nigeria: Federal, State, and Local Expenditure Assignments
Foreign affairsFederal
International tradeFederal
Interstate tradeFederal
Air and rail transportFederal
AgricultureFederal and state
EducationFederal and state
HealthFederal, state, and local
Natural resourcesFederal, state, and local
HighwaysFederal, state, and local

The structure of government expenditures has changed markedly in recent years. Up to 1993, the share of federal expenditures in total outlays increased, at the expense of the share of the states. At the same time, local government expenditures rose somewhat, but by less than the increase in their revenues. The growth of extrabudgetary expenditures of the federal government, from less than 1 percent of GDP in 1987 to over 11 percent of GDP in 1993, was the primary cause behind the rise of the share of federal expenditures in total spending. This reflected increased outlays for the construction of the new federal capital in Abuja, for elections of state and local governments, for a number of large capital-intensive projects, and for petroleum and fertilizer subsidies. Furthermore, the depreciation of the naira has contributed to a substantial increase in foreign-exchange-denominated expenditures, which are concentrated in the federal budget. Foreign interest payments in the federal budget, for instance, amounted to an annual average of 6.5 percent of GDP for 1990–94. More recently, however, federal expenditures appear to be better controlled, with total outlays declining from some 33 percent of GDP in 1993 to just 14.7 percent of GDP in 1995.

Tax Assignment

The Constitution specifies the distribution of taxation authority between the three levels of government (Table 3). The federal government has the power to legislate (and collect) import and export duties, excises, mining rents and royalties, petroleum profit taxes, and the value-added tax, the proceeds of which, however, are shared by all governments as part of the Federation Account. In addition to its share in the Federation Account, a few other revenues are assigned to the federal government. These include personal income taxes levied on the armed forces, dividends from public enterprises, and sales tax revenue from the federal capital territory.

Table 3.Nigeria: Federal, State, and Local Tax Jurisdiction and Assignment
TaxLegal JurisdictionCollectionRetention
Import dutiesFederalFederalFederation Account
Excise dutiesFederalFederalFederation Account
Export dutiesFederalFederalFederation Account
Mining rents and royaltiesFederalFederalFederation Account
Petroleum profits taxFederalFederalFederation Account
Capital gains taxFederalStateState
Personal income tax1FederalStateState
Sales taxFederalStateState
Company taxFederalStateState
Stamp dutiesFederalStateState
Gift taxFederalStateState
Property taxStateStateState
Licenses and feesLocalLocalLocal
Motor park duesLocalLocalLocal
Motor vehicle taxStateLocalLocal
Source: Presidential Commission on Revenue Allocation (1980), Vol. 1, Main Report.

Personal income taxes of the armed forces, external affairs, and the Federal Capital Territory are federally legislated, collected, and retained.

Source: Presidential Commission on Revenue Allocation (1980), Vol. 1, Main Report.

Personal income taxes of the armed forces, external affairs, and the Federal Capital Territory are federally legislated, collected, and retained.

While the states remain largely dependent on revenues from the Federation Account (deriving nearly 90 percent of their revenues from this source), there has been some effort towards developing revenue sources outside of the revenue-sharing pool, and the personal income tax and the company tax have become major sources of independent revenue for the states. Other independent revenues include the capital gains tax, the purchase tax, stamp duties, the gift tax, and the property tax. While states have the legal jurisdiction for the setting of rates and the power to define the tax base for smaller taxes such as property taxes, motor vehicle taxes, and entertainment taxes, this jurisdiction belongs to the federal authority with respect to all other taxes, even relating to those collected and retained by the states (see Table 3). Local government revenues outside the revenue-sharing arrangement are small—but potentially buoyant—and include market and trading license fees, motor parking dues, and motor vehicle taxes.

Nigeria’s excessive reliance on oil revenues over the years has delayed needed improvements in non-oil revenues. As a consequence, revenues of all levels of government have become highly dependent on developments in the oil sector. Federally collected revenues, including from petroleum, showed steady increases during the oil boom years of 1974 to 1980, while there was a steady decline in the first half of the 1980s, as oil prices began to fall. Subsequently, federally collected revenues increased from 22 percent of GDP in 1986 to 28 percent of GDP in 1993, partly reflecting a rise in petroleum tax and nontax proceeds and the devaluation of the naira; however, these revenues declined to an average of 22 percent of GDP during the subsequent two years, again reflecting developments in the oil sector. During this period, revenues from the company income tax and customs and excise taxes remained at their traditional levels, equivalent to about 1.1 and 2.7 percent of GDP, respectively.

In recent years, accounts have been set up under the broad category of the Federal Stabilization Account. These accounts introduced first in 1989 by the military government, primarily to sterilize windfall oil revenues and to act as financial cushions in the event of a decline in oil prices, have been allocated a significant share of the Federation Account.3 However, while there have been statutory allocations to the lower levels of government, the accounts have largely been used to finance supplementary outlays and extrabudgetary operations of the federal government. Accordingly, they have been ineffective as a stabilization tool. For example, in 1993, the surge in extrabudgetary outlays was instrumental in the sharp acceleration of inflation (from 13 percent in 1991 to over 57 percent in 1993). Subsequently, the decline of this expenditure category, from 11.5 percent in 1993 to an average of 0.3 percent of GDP in 1994—95, helped to reduce the fiscal deficit from almost 18 percent of GDP in 1993 to 3.7 percent of GDP in 1995.

Financing Arrangements

There are three main avenues through which federal, state, and local governments in Nigeria finance their expenditure needs. These are an intergovernmental revenue-sharing arrangement, transfers, and borrowing.

Revenue Sharing

Revenue sharing features prominently in the intergovernmental relations in Nigeria. The current basis for revenue sharing of federally collected revenues among the federal government, states, and local authorities is the Revenue Allocation Act of 1981. With effect from June 1992, federally collected revenues that accrue to the Federation Account are shared among the three tiers of government with 48.5 percent to the federal authority, 24 percent to the states, 20 percent to local governments, and 7.5 percent to other extrabudgetary funds. The revenues accruing to the states are allocated by using a formula that takes into account a number of factors. The weights used in allocating the proceeds of the Federation Account across states are 40 percent, shared equally, to meet the minimum responsibilities of state governments; 30 percent, based on the size of the population; 10 percent, based on geographic size; 10 percent, based on social development needs; and 10 percent, based on the state’s internal revenue mobilization effort. A similar approach is used to distribute the local governments’ share in the Federation Account.

Revenue sharing has been a key factor in the development of fiscal federalism in Nigeria. Its origins date back from the colonial era, when in 1946 regional councils were established for the Northern, Western, and Eastern regions. The regional councils initially played an advisory role and had only limited fiscal responsibility, but they were eventually given the power to raise taxes and to appropriate independently collected revenues for their particular regions. At the same time, federally collected revenues were allocated to the regions based on a principle of derivation, whereby tax receipts are allocated in accordance with the revenue-generating activities of each region. The states’ needs, as measured by population and national interest, were given relatively minor weights. Together with ad hoc considerations incorporated in the revenue-sharing formula, this led to controversies and political strife among the regions.

By 1966 the revenue-sharing scheme was expanded to include proceeds from import and export duties, excises, mining rents, and royalties. The regional governments were allocated, based on the derivation principle, all federally collected revenues from these taxes and 50 percent of revenues from mineral royalties and rents. The distributable pool account, the predecessor of the Federation Account, was created during this period, from which allocations were based on population size and equalization criteria. In addition, the regions were allowed to collect and retain the personal income tax, licenses and user fees, and property taxes.

The military government significantly altered the tax levying authority and the revenue-sharing arrangements of the federal and regional governments. The military reduced the importance of the derivation principle in revenue sharing and the associated income disparities that existed among the states by increasing the share of proceeds accruing to the distributable pool account, particularly from import duties and excises on petroleum and tobacco products and export duties. In addition, in an effort to strengthen the financial position of the federal authority, all tax revenues accruing from off-shore oil production, which previously had accrued to the states on the basis of derivation, were reserved for the federal government.

With economic growth and increased oil production, the tax base of the federal government widened during the military era. At the same time, the expenditure requirements of the regional governments increased, relative to their independently collected revenue base. Accordingly, during the 1970s the states became increasingly dependent on federally collected repeated revenues, including a reassignment of some of their taxation functions to the federal authority. In addition, this period witnessed the decline of the derivation principle in determining revenue sharing. Other criteria such as absorptive capacity, the need to achieve and maintain minimum standards for national integration, equality in access to development opportunities, independent revenue effort, and fiscal efficiency became the major determinants.

The past years have seen a change in the structure of revenue sharing. Recent figures indicate that the share of the federal government in the proceeds of the Federation Account has declined from about 75 percent in 1980 to just over 50 percent in 1994.4 State governments’ share of the account has been fluctuating at about 25 percent for the same period. At the same time, local governments have increased their entitlement from close to zero in 1980 to 20 percent by 1994.

Owing to these developments in the revenue-sharing scheme, a restructuring of total revenue has occurred among the three tiers of government. Federal and state government revenues as a percent of total government revenues have declined, while the local governments’ share has increased substantially, as a result of the increase in the statutory allocations, and also because of some increase in independent revenues.

Intergovernmental Grants and Transfers

Along with the revenue-sharing arrangement, there is also a system of nonstatutory and discretionary transfers, albeit of lesser importance than the former. There are two kinds of discretionary transfers. Discretionary recurrent transfers from the federal government to lower levels of government are made to meet specific recurrent needs such as the transfers in the context of the universal primary education scheme. Discretionary capital transfers can be either federal grants given for specific purposes in the context of the national development plan to finance investment expenditures, or transfers that represent on-lending of borrowing by the federal government.

There are also transfers from the state and local governments to the federal government. Beginning in 1989, the federal budget was increasingly coming under pressures, while the state and local governments registered surpluses. Accordingly, during this period transfers from the lower levels of government to the federal government have been made through the Federal Stabilization Account. For example, in 1992, these transfers to finance the federal budget amounted to about 4 percent of GDP.


Prior to 1977, the federal government was the only public authority to contract domestic or foreign loans. Federal government long-term bonds and short-term treasury bills were issued, with the proceeds shared between the federal government and the states on a 40 percent and 60 percent basis, respectively. During the 1970s, when the federal government registered surpluses reflecting increases in oil revenues, substantial amounts of such loans were made to the states, which were later mostly written off as grants. Following the reforms of the Nigerian financial system in 1977, bank financing of state budgets was permitted, and state and local governments were allowed to issue securities to financial institutions. Also, foreign borrowing by states under federal guarantee was authorized, while the ban on the sale of debt instruments to the nonbank public by other than the federal government remains in force. More recently, based on ad hoc decisions by the military government, strict limitations have been placed on domestic borrowing by the states and the federal guarantee for external financing is no longer valid.5

Tax Administration

The responsibility for tax administration in Nigeria is shared mainly on the basis of the relative efficiency of the federal government and the state and local governments in collecting taxes. Oil taxes, which constitute the major portion of government revenue, are collected by the federal government, as are customs, excise, and export duties.

Oil revenues derive from two sources: the operations of the private oil companies, and the Nigerian National Petroleum Company (NNPC). The private oil companies are permitted to withhold certain amounts from their export proceeds to cover their costs, including profits, and are obliged to deposit the remainder in a U.S.-dollar-denominated Central Bank account from where the proceeds are transferred to the Federation Account. A similar procedure is applied to the NNPC’s export proceeds. The surplus from NNPC’s domestic operations is transferred to the Federation Account at the end of each month.6

Each month at a meeting of the Revenue Allocation Committee, the balance in the Federation Account is allocated according to statutory shares between the federal government, the state and local governments, and the Federal Stabilization Account. As indicated above, the federal government and the state and local governments also collect revenues that do not enter the Federation Account.

While indirect tax administration has improved with the introduction of the VAT (although other difficulties still remain with the rate and threshold of the tax), the administration of direct taxes appears to have weakened. This is primarily due to the fragmented administration and legislative arrangements between federal and state authorities. Tax avoidance and evasion, particularly with respect to personal and company income taxes, have become pervasive. A more uniform legislation to provide a transparent legal basis for income taxation across states, improved coordination between state and federal tax authorities, and the expansion of joint training and tax audits would enhance the effectiveness of federal and interstate tax administration.

Budget Formulation and Implementation

The Nigerian fiscal year coincides with the calendar year. The federal government budget is formulated beginning in October and normally is adopted by the end of February.7 The federal government’s expenditures are controlled by a system of quarterly warrant releases8 to all government ministries for budgetary items. Extrabudgetary expenditures also require a warrant for additional incurred expenditures.

In addition, the federal government has established and controls five special funds that are outside the federal budget: the General Ecology Fund, for addressing ecological problems; the Federal Capital Territory Fund, for the construction of the federal capital at Abuja; the Mineral Derivation Fund, for the specific benefit of mineral-producing states; the Development of Mineral Producing Areas Fund; and the Statutory Stabilization Account, which serves as a form of savings. In total, the special funds received more than 7 percent of the Federation Account revenues. While these funds primarily finance investment expenditure, at times they have generated large surpluses that have been invested in government paper.

The budgetary process of the state governments is similar to the federal system discussed above. State budget estimates are prepared and funds are withdrawn from the State Consolidated Revenue Fund based on appropriation bills authorized by the State Assembly and backed by spending warrants. However, the state government’s budgetary flexibility is relatively limited as much of their resources derive from the Federation Account.

At the local level, however, expenditure management is controlled by financial regulations formulated by the relevant state. Elected local government councils submit their budget to a state ministry for approval. Except for the Lagos city council, which has a financially competent expenditure management system, finances of local governments are for the most part regulated by the states, largely as a result of limited capacity.

Macroeconomic Management

There are many arguments in support of the presumption that in a federal system fiscal stabilization policies should be assigned to the center, and the key role of the federal government in macroeconomic management has never been questioned in Nigeria.

Effective macroeconomic management by the federal government requires that taxes are at its disposal that are both relatively flexible and large in size in relation to the national economy. The federal government must be able to take tax measures that affect aggregate demand and the fiscal balance quickly and significantly. In this context, the federal government’s authority over the stabilization account and other funds such as the PSTF, its ability to change the distribution of revenues from the Federation Account, and its retention of control over the tax rates for the VAT and the company income tax augurs well for the execution of demand management policies. On the other hand, the federal government’s ability to pursue effective fiscal stabilization policies may be constrained, since many of the major taxes it controls are either collected and retained by the states or pass through the Federation Account. The exclusive assignment of broad-based taxes to the federal government may be called for from a macroeconomic point of view in order to enhance the scope for timely and effective fiscal stabilization measures. In this connection, however, it should be noted that the state sales tax was replaced by a central VAT effective January 1, 1994. While a VAT is typically a broad-based tax with considerable revenue potential, the tax introduced in Nigeria applies to less than half of private consumption and has a low tax rate (5 percent). While 80 percent of the revenue collected from the VAT was originally transferred to the states, the 1996 budget changed the allocation to federal, 35 percent, state, 40 percent, and local governments, 25 percent.

As regards expenditures, the federal government is empowered to approve or reject the budget of state authorities, a fact that provides some leverage to the center on state fiscal policies. In addition, nonstatutory transfers from the federal to lower levels of government for purposes of specific recurrent and capital expenditures give the federal government some influence on the spending behavior of subnational governments. Nonstatutory transfers to the subnational governments can play a useful role in macroeconomic management, as their level and timing can be adjusted to some extent to conjunctural requirements.

With regard to its own finances, the federal government’s practice of using the Federal Stabilization Account for the financing of off-budget items and the distribution of the statutory shares of the states on an ad hoc basis may not be conducive to fiscal discipline. This account should be used as intended for siphoning windfall oil revenues and encouraging revenue diversification. In general, the proliferation of extrabudgetary funds presents a problem for effective budget management. These funds reduce the transparency of the budgetary process and create loopholes for government operations not approved through the proper (budgetary) channels, undermining the use of the budget as a macroeconomic instrument.9

Following the reform of the financial system in 1977, borrowing by state and local governments has become possible. While state and local governments have been registering fiscal surpluses in recent years, relatively easy access of subnational governments to borrowing has nevertheless increased the risk that the federal government’s stabilization efforts may be compromised in the future by excessive borrowing of state and local governments.

Structural Issues

As discussed earlier, revenue sharing plays an important role in financing state and local expenditures in Nigeria. Like unconditional grants, revenue sharing is intended to provide subnational governments with the ability to supply public goods and services independently of their taxable capacity. It is particularly important in a country such as Nigeria, with geographically concentrated and large natural resources. Not surprisingly, the question of how revenues should be shared among regions has always been a controversial issue in Nigeria.

To avoid vertical fiscal imbalances, the expenditure responsibilities of the different levels of government have to match their revenue-generating capacities taking into account both shared and other revenues. The recent increase in extrabudgetary expenditures of the federal government would indicate a mismatch of assignments and a need to review the present arrangement. In addition, when the federal government delegates a particular function (for example, agricultural development) to a lower level of government, a corresponding revenue source should be assigned taking into account the administrative capacity of the state and local governments. Also, exchange rate movements tend to have different impacts on federal, state, and local finances. A depreciation of the naira, as witnessed over the past years, tends to improve state and local finances, because state and local governments have only few foreign exchange expenditures, while the impact on the federal budget is less clear, given the large amount of foreign exchange expenditures, including debt service.

With Nigeria currently in the process of redefining political and legal authority under a new constitution, a thorough review of the requirements and obligations of all three levels of government is important. This should take into account, inter alia, Nigeria’s vulnerability to changes in the world market price of oil, the treatment of extrabudgetary expenditures of the federal government, and the impact of exchange rate movements on federal, state, and local finances. In this context, particular attention should be paid to further enhancing the stabilization function of the federal government.

In view of the dynamic nature of fiscal federalism, the development of institutions to coordinate and oversee intergovernmental relations on a permanent basis is critical. In Nigeria, the advisory body concerned with intergovernmental fiscal relations is the National Economic Council, which was created in 1955. Its membership consists of cabinet ministers and state governors and it is chaired by the Prime Minister; however, the Council meets infrequently, which limits its effectiveness. Accordingly, there is also a need for a permanent fiscal commission that can periodically review the federal system and recommend modifications to the revenue-sharing arrangements based on changing economic conditions.

The author is particularly indebted to Christian Schiller for his substantial input and editorial support.

For a description of the Nigerian federal structure and finance see Ashwe (1986).

While revenue distribution from the value-added tax (VAT) is as indicated above, the allocation to the Federation Account does not include the amount corresponding to the value of certain “priority expenditures,” as noted in the annual budget.

In effect, there are two active accounts under the auspices of the Federal Stabilization Account; for the first account, established by the military government in 1989, both withdrawals and allocations were made on an ad hoc basis, while for the second account, set up under the 1989 Constitution, an allocation was made amounting to 0.5 percent of the Federation Account revenue.

The calculation here includes the share of the Federal Stabilization Account, while in Table 1 this is shown as a separate item.

Debt statistics for state and local governments are not readily available. Nonetheless, with lower levels of government consistently showing a budgetary surplus in recent years (Table 1), and with the monetary accounts for 1995 indicating only 0.2 percent of GDP in outstanding net credit to these governments, the threat to macroeconomic stability appears minimal.

In this connection, the additional revenue accruing from the October 1994 adjustment of petroleum prices was allocated, in part, to the Petroleum Special Trust Fund (PSTF) to be utilized for special capital projects and social services. The PSTF began operations in January 1995 and is directly accountable to the Head of State.

Under the present system, without a functioning parliament, the budget is approved by the Provisional Ruling Council and announced by the Head of State.

A warrant authorizes the Accountant-General to issue funds and the accounting officer of the relevant ministry or agency to incur expenditure (see Oshisami and Dean, 1984).

During 1988–94, about US$12.4 billion was allocated to a variety of projects and other outlays outside standard budgetary procedures. In 1995, however, budgetary transparency improved when all dedicated accounts were closed and revenues accruing to these accounts became incorporated into the federal budget.


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