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.