Comment on FR Doc # 2010-30500

The proposed rule should be implemented ONLY IF it can be demonstrated that the Internal Revenue Service will reduce its personnel costs and/or otherwise reduce its expenses (and therefore its budget) by an amount which will more than offset the costs which the IRS is transferring back to tax return files and tax return preparers. Electronic filing requires additional time and expense by return preparers to: a) enter additional data from W-2's and 1099 forms and schedules of security transactions b) obtain a signed Form 8879 from the taxpayer indicating the return is correct c) submit the proposed return to the electronic return originator for various tests prior to submission to the IRS d) correct any errors in the electronic files before submission of the return to IRS and later checking to see if IRS accepted the return and if so, notifying the taxpayer e) incur additional fees by the electronic return originator for the electronic filing. I estimate the above to be from $25 to $35 per return. If this rule passes, the additional time and expenses must be borne by the taxpayer and/or the tax preparer. If the Internal Revenue Service cannot demonstrate that it will reduce its costs and budget by an amount exceeding the costs being passed through, then the American public will be bearing the expenses twice. The proposed savings are (a) one less paper return to print and (b) no postage being required. Paper costs are very minimal. And with less postage being purchased, the American public will be forced to subsidize the U.S. Postal Service even more than it is already. So there is no savings on postage.