Comment on FR Doc # 2011-10758

Document ID: IRS-2011-0009-0008
Document Type: Public Submission
Agency: Internal Revenue Service
Received Date: July 11 2011, at 12:00 AM Eastern Daylight Time
Date Posted: July 12 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: May 9 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: August 8 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80ec0043
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Need to define services: examples of check for over $10,000: Law Enforcement-contract with county; Sewer Treatment-Contract with other agency; Water procurement-various public agencies and joint ventures, some entities might purchase water from public water companies; Water can get complicated as to what part of the bill is for services, capital contribution to joint venture, maintenace charges, there are "take or pay" provisions in agreements, basin replenishment charges are all part of cost of water; Electric services for street lights, buildings, water pumping and booster stations...etc alway over $10,000 is paid weekly-paid to private company; contract Software services-annual maintenance agreement, license renewal; Crossing guard contract with school district; Retirement payment to retirement systems is this a service?; Contract city attorney(s); Engineering sevices provided by third party under contract; Landscape services?; Health premium to private and govt agency (CalPERS); Wildland fire protection services under contract with fire special district; purchase of vehicles and equipment (car dealers have been hurt enough in the recession); Election services paid to County Registrar of Voters; Human services provide under contract with another City; Payment under developer reimbursement agreements-for construction of backbond infrastructure- we owe developers from the 1980s that will be paid from future development; Insurance provided by a Joint Powers Authority; For the $100M threshold our expenditures float above and below depending on capital improvement projects underway. We won't know if we spent over $100m in a given year until after the year is over. Another issue is that payments maybe delayed or accelerated to avoid the over the $100M theshold in a given year.

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