Comment on FR Doc # E7-25134

The new 941x is a definite improvement over the old 941c process, particularly in that we do not need to wait to file a correction until a current 941 is due. It will also certainly help avoid confusion surrounding adjustments being inadvertantly applied to incorrect tax periods. The only negative I see is that you are not allowing refunds to be claimed if the 941x includes both positive and negative adjustments that have an end result in Box 17 of a refund. Instead you are forcing employers to take it as a credit on their current quarters return. This creates GL difficulties when correcting prior years, and does not eliminate the problem of employers having to continue to track these corrections until their current quarters 941 is filed in order to properly take the credit. I foresee a lot of employers forgetting to include the credit from a previously filed 941x and consequently overpaying in the current quarter, which will result in your having to issue refunds anyway. It seems like this will still create unnecessary work for both your agency and employers.