Comment on FR Doc # 2010-18198

While I fully agree with the new testing and PTIN requirements, I do not agree with the fee charged for the PTIN. As a CPA, I have to renew my license annually, which includes, among other things, fees. Having the additional expense of re-registering my PTIN seems redundant in that regard. For those preparers who have no licensing requirements, I can certainly understand assessing a fee, if for no other reason than to make them value the responsibility they hold. However, by abiding by my state licensing requirements, I feel I already meet this obligation. Just as with the testing requirements there is a waiver for those who have already passed a test to obtain their license, so should there be a waiver for those paying to maintain that license. Perhaps the waiver could be for those licensed practitioners who maintain a certain percentage of their required CPE in the area of taxation. I do not foresee an added documentation burden on the IRS, as such documentation could simply be kept by the practitioner, and the IRS could audit a certain percentage of practitioners as it deems necessary. This is the procedure followed by my state regarding CPE documentation. I submit a list of the courses I have taken, but no proof is otherwise provided to the state. They have the right to audit my supporting documents as they see fit. I realize that there is not an answer that will appeal to everyone affected, but I appreciate your taking my comments into consideration.