Comment on FR Doc # E7-08378

Thank you for this last minute consideration. I have spent the last 25 years as a Correspondence Examination Technician doing audits by mail / phone; I just celebrated 35 years of service to the Internal Revenue Service two days ago. I have performed thousands of audits of this classified issue of dependent exemption: the King decision, after 3 years, has influenced this change in the Form 8332 I think that the new "Nights" provision will have an impact based on: (1) The logic of using 'nights' instead of days will cut down on the number of misinterpretations in the law. Children need their sleep at night, they sleep at their residence. 8-10 hours for youngsters is over a third of the day; if attending school / day-care, the child would not be home. If a child lives at home, the person working during the DAY usually has control of deciding the 'away from home' daytime caretaker / school. (2) The number of audits with self-serving statements from day-care / schools of "this person drops off / picks up" the child will (or should) drop off. The fact that someone drops off a child doesn't mean the child lived with them. This will reinforce better school records. ANECDOTAL NOTE: In the past few years, more schools have listed both parents on their records, but this is for emergency information. Very few schools now show from which address the child attends school. States (like Missouri) require the child to attend the school from an address within its district (535 Missouri school districts, the largest number, per capita, of school districts in the US) or else the parents pay the tuition... (3) People working nights to "get ahead" -- (advanced schooling, better night pay, etc.) will have a tougher time if they drop their child off at 9PM at the other parent's residence, pick the child up at 5AM and trundle them off to school. This adversely affects the poor. However, a simple statement from the employer(s) that they worked so many hours at night during the year would resolve a question of this nature. This leaves the 'night' provision open to that interpretation by the other parent. Again, the school statement / daycare statement becomes more important for consideration. (4) The fact that grandmother has grand-maternal rights to exercise from a court order only means that the time away from mom or dad is taken away from each equally. If it gets involved with a multiple grandparent grand-parenting rights (4 separate times / residences) and parental rights (2), this will have to be crossed by Appeals / Courts. I should then wish that a multiple support agreement would be encumbered by all these parties. It could be so stated in the regulations, that (yet) a different form would have to be filled out to show which grandparents' / parents' rights are not being trampled upon--but by mutual agreement. (No more Solmon.) (4) Separate sections for signing for one year and for all future years will be worthless without a definite social security number and name for each party on the Form 8332. Many times, 2 or 3 childrens' names / some SSN's are squeezed onto one Form 8332. This needs to be addressed more aggressively, a separate form for each child or the form is null and void.