Prior to its
next submission for renewal, OMB would like TTB to address the
public comment suggesting that the form be amended to recognize the
representation of industry members by law firms instead of only
individual attorneys. If TTB concludes that amending the form in
this way would be legally impermissible, problematic and/or
unnecessary, Treasury shall provide supporting justification for
this in the supporting statement of its next submission. Requiring
representation by only individual attorneys could potentially be
problematic; if the attorney representing the industry leaves the
law firm that the industry uses, they are still considered by TTB
as the representing attorney. This could lead to multiple issues
with improper disclosure (i.e. sharing of proprietary information),
and administrative burdens imposed on industries of having to keep
track of individual attorneys at the law firms they use. We feel
that TTB needs to properly address these issues before its next
submission.
Inventory as of this Action
Requested
Previously Approved
05/31/2014
36 Months From Approved
05/31/2013
10,000
0
10,000
3,250
0
3,333
0
0
0
TTB F 5000.8 delegates the authority
to a specific individual to sign documents on behalf of an
applicant or principal. 26 U.S.C. 6061 authorizes that individuals
signing returns, statements, or other documents required to be
filed by industry members under the provisions of the IRC or the
FAA Act, are to have that authority on file with TTB.
Decreased with the introduction
of PONL. This decrease was predicted when we included this form in
our PONL system and we estimate that it is accurate now.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.