Internal Revenue Service

CC:PA:LPD:PR (REG-149856-03) Room 5203

PO Box 7604, Ben Franklin Station

Washington, DC 20224

Attn:   CC:PA:LPD:PR (REG-149856-03)

Re:     Proposed Regulations on Special Rule for Children of Divorced or Separated Parents or Parents Who Live Apart

Dear Sir or Madam:

The American Institute of Certified Public Accountants appreciates the opportunity to comment on the proposed section 152 regulations on a special rule for children of divorced or separated parents or parents who live apart. Our comments were prepared by members of the Individual Income Tax Technical Resource Panel and approved by the Tax Executive Committee.

The AICPA is the national, professional organization of certified public accountants comprised of more than 350,000 members. Our members advise clients on federal, state, and international tax matters, and prepare income and other tax returns for millions of Americans. They provide services to individuals, not-for-profit organizations, small and medium-sized businesses, as well as America's largest businesses. It is from this perspective that we offer our comments.

We would be pleased to discuss these comments with you or a member of your staff at any time. If we can be of further assistance please contact me at jeffrey.hoops@ey.com; Lorraine Evans, Chair, AICPA Individual Taxation Technical Resource Panel, at lorraine@motesevans.com; or Lisa Winton, AICPA Technical Manager, at lwinton@aicpa.org.

Sincerely,

Jeffrey H. Hoops

Chair, AICPA Tax Executive Committee

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