Comment on FR Doc # 2010-22793

I aggree with The IRS and Department of Treasury belief regarindg this issue. First, domestic series generally should be treated, for Federal tax purposes, as entities formed under local law. Second, overall, the factors supporting separate entity status for series outweigh the factors in favor of disregarding series as entities separate from the series organization and other series of the series organization. Finally, domestic series should be treated as a separate local law entity even if its business purpose, investment objective, or ownership overlaps with that of other series or the series organization itself. Furthermore, I am think more though needs to be taking into the ruling. The idea that an election, agreement or other arrangement that permits debts and liabilities of other series or the series organization should be enforceable against the assets of a particular series is manageable. Also to enforce a rule that if an entity fails to comply with the record keeping requirements for the limitation on liability available under the relevant series statute, WILL NOT prevent a series from meeting the definition of “series” in the proposed regulations is very a great balance. in addition i feel that the series should be treated as the owner of the assets for Federal tax purposes if it bears the economic benefits and burdens of the assets under general Federal tax principals.