May 21, 2008

IRS
Draft 2008 Form 990 Instructions
1111 Constitution Ave., NW.
Washington, DC 20224

Attention:  SE:T:EO

RE:     Instructions for Form 990, Return of Organization Exempt from Income Tax

Dear Sir:

The AICPA is the national, professional association of CPAs, with approximately 350,000 members, including CPAs in business and industry, public practice, government, and education; student affiliates; and international associates. Our members provide audit and tax services to thousands of not-for-profit organizations.

The attached commentswere developed by our Form 990 Instructions Task Force made up practitioners who serve tax-exempt organizations and are experienced with both the nuances of the Instructions and the challenges that arise for taxpayers in applying them. The comments were approved by our Exempt Organizations Technical Resource Panel.

We look forward to working with you in the future on this matter. We stand ready to discuss and explain our comments with you at any time. If you have any questions, please contact either of the undersigned: Marie Arrigo at MArrigo@eisnerllp.com, or Jane Searing at JSearing@clarknuber.com; or George White, AICPA Technical Manager, at gwhite@aicpa.org.