Comment on FR Doc # E9-05951

March 24, 2009 Mr. Douglas Schulman Commissioner CC:PA:LPD:PR [REG-158747-06] Internal Revenue Service, Room 5205 P.O. Box 7604, Ben Franklin Station Washington, DC 20044 RE: Withholding Under Internal Revenue Code Section 3402(t); Hearing Dear Mr. Schulman: On behalf of the National Association of State Auditors, Comptrollers and Treasurers, we submit the attached outline conveying our desire to provide testimony at the April 16 hearing regarding Section 3402(t). Our comptroller members have the direct responsibility for running the state’s accounting system and will be responsible for conducting Section 3402(t) reporting, withholding and remittance. We appreciate your holding a hearing on this important issue and hope that you will gain a better understanding of the numerous issues facing state governments. I. Reporting Capability and Process : State Accounting /Procurement Systems – 2 minutes • Existing process for conducting 1099 reporting (Gathering vendor information, matching, error correction process) II. Withholding Capability and Process – 7 minutes • General capability/process/reconciliation/disbursement • Specific Hurdles: Credit and debit card transactions Exceptions in statute (needs based services and providers) Existing contracts • Timing for modification or purchase of new systems and or component • Liability III. Conclusion – 1 minute • Timing and recommendation regarding implementation Should you have any questions, please contact me at cchebinou@nasact.org or 202-624-5451. Cornelia Chebinou Washington Director