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P. 57
To a certain extent, payees
always do have an indirect
"involvement" and
"participation" in the
transaction where the benefits
they received are disallowed
because the accounting
recognition of the release of
funds and their mere receipt
thereof results in the debit
against government funds in
the agency's account and a
credit in the payees' favor.
Notably, when the COA
includes payees as persons
liable in an ND, the nature of
their participation is stated as
