Comment on FR Doc # 2012-06072

1 Is it really necessary to have this info. 2 Why don't you just refer to the last tax return filed under that number. It's all there. 3 Cost assumptions are unreasonable: a IRS cost to mail is at least $1,600,000 at a cost of $1 per letter for forms, postage and handling. b. IRS cost to remail unreturned forms + $800,000. c. IRS cost to process returned form at $5 per form = $8,000,000. d. Cost to client to find out what is going on (because they are not accountants or lawyers and they don't have the time) will iclude at least 10 minutes of their time to call the accountant and send it to him, field his return phone call and tell him to take care of it. (1,600,000 at 1/6 hour at $80.00 per hour = $21,333,333.33) + mailing (1,600,000 @ 50 cents = $800,000). e. Accountant cost of 2 phone calls and research about some new form that doesn't mean anything. (400,000 accountants at 1/2 hour at $150,000 per hour = $30,000,000.) f. Accountant cost to fill out and file forms at IRS estimated time. (1,600,000 @.25 hrs @ $150 per hour = $60,000,000) + mailing at $.50 per form - $800,000. Putting this all together brings the cost at over $100,000,000. THIS IS MATERIAL. Actually the total cost will probably rurn significantly less than this because the rate of non compliance will be very high. Finally, I may want to reverse my comments on this because I am an accountant and I bill at $200.00 per hour. This seems like a real money maker for us accountants. Will any one else benefit.