Comment on FR Doc # E8-30712

On behalf of KPMG LLP, I submit this request to testify at the hearing scheduled for April 21, 2009 concerning REG-144615-02 (Prop. Reg. § 1.482-7), and I submit the following outline of issues, which we would like to discuss at the forthcoming hearing: 1. Platform contributions and financial statement goodwill 2. Definition of “divisional interests” 3. Factors affecting reliability of financial projections 4. Determination of a pre-tax amount 5. Treatment of make-sell rights 6. Reliability of the acquisition price method 7. Application of the periodic adjustment rule 8. Changes in the scope of the IDA 9. Definition of “capability variation.” Additional comments and analysis may be found in an article on these regulations prepared by Tom Zollo, Clark Chandler and myself, which will be published in the May 2009 issue of Taxes magazine.