Internal Revenue Service

Courier’s Desk

1111 Constitution Avenue, N.W.

Washington, DC 20224

Attn:  CC:PA:LPD:PR (REG-105847-05)

Re:  Proposed Regulations relating to the Deduction for Income Attributable to Domestic Production Activities (REG-105847-05)

Dear Sir or Madam:

The American Institute of Certified Public Accountants (AICPA) offers the enclosed comments on REG-105847-05, and section 199.  The AICPA is the largest professional association of certified public accountants in the United States, with more than 350,000 members in business, industry, public practice, government, and education.

We commend the enormous effort put forth by the Internal Revenue Service (Service) and the Treasury Department (Treasury) in providing guidance with respect to section 199.  We offer these comments to assist the Service and Treasury in developing clear and administrable rules that incorporate safe harbors, simplifying assumptions, and de minimis rules, as appropriate, to reduce controversies and the attendant compliance and administrative costs.

The enclosed comments were developed by members of our Tax Accounting Technical Resource Panel and approved by the AICPA Tax Executive Committee.  We would be pleased to offer further assistance or discuss these comments with you or a member of your staff at any time.  If you have any questions, please contact me at tpurcell@creighton.edu; or Barry Tovig, Chair, AICPA Section 199 Task Force, at barry.tovig@ey.com; or George White, AICPA Technical Manager, at gwhite@aicpa.org.

Sincerely,

Thomas J. Purcell III

Chair, AICPA Tax Executive Committee

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