Comment on FR Doc # 2010-18198

Dear Ms Lesniak, Thank you for hopefully reading this. To begin mandating user fees for basically an EIN number is a great way to raise funds for what purpose? To ensure that qualified members in good standing with state and federal societies pay more to do their job of fair reporting to governmental agencies. The long held position of more oversight to discourage the bad guys is as effective as putting a cap on a well that has already done 20 years of environmental damage. The problem is out there - but charging folks a fee to register - particularly those registered for years - does nothing to ensure the public that I'm a good guy or a bad guy. It creates more unnecessary oversight without dealing with the real issue, that bad preparers stay under the radar screens of those already authorized to get them - The agencies requesting the returns. I'm a 30 year practitioner. I've seen many new fees show up over the last two years - by the state of Michigan and MACPA to do what - the same thing this proposed rule is attempting to do - make it more difficult for the bad guys to exist. Lets take our collaborative efforts annd money and do something nobel - Institute procedures that go directly after the problem - more sting operations. The culprit is not invisible - they file returns - you know who they are. Enough of the drama here. Just put this in the pile along with the others who think this idea - to tax the good guys - is counterproductive to all. Thank you for your time. Donald Heriford, CPA