Comment on FR Doc # E8-28789

Section 511 imposes a massive unfunded mandate and will cause significant administrative and other financial burdens, including the cost of revising our accounts payable system to implement the new law. We are a small city with a very small accounting staff, and tax reduction initiatives (popular in Washington State) inhibit our ability to keep up with our already growing workload as we do not have the financial capacity to add staff. Additional cost will also be borne by the city of Everett due to the fact that the costs for doing business with us will increase, and private sector companies are sure to pass those costs along. State and local governments are already required to assist the IRS in its collection duties by reporting payments to corporations and individuals. It is our understanding that there is no evidence that this reporting is insufficient to identify noncompliance by state and local contractors. This new withholding provision is merely a new mechanism for facilitating tax deposits, which shifts the burden of collection from the federal government to state and local governments at a significant cost. We respectfully request that you reverse this decision.