CUNA Comment Letter

IRS Form 1099-C, Cancellation of Debt

August 18, 2008

R. Joseph Durbala
Internal Revenue Service
1111 Constitution Avenue, NW, Room 6129
Washington, DC 20224

RE:     IRS Form 1099-C, Cancellation of Debt; OMB Number 1545-1424

Dear Mr. Durbala:

The Credit Union National Association (CUNA) appreciates the opportunity to comment on the Internal Revenue Service’s (Service’s) request for comment on Form 1099-C, Cancellation of Debt (Form 1099-C). By way of background, CUNA is the largest credit union trade organization in this country, representing approximately 90 percent of our nation’s 8,200 state and federal credit unions, which serve 91 million members.

The Department of Treasury and other federal agencies are required by the Paperwork Reduction Act (PRA) to obtain approval from the Office of Management and Budget (OMB) for the collection of information. The PRA requires each federal agency to publish for public comment information collection requests and to consider the impact of paperwork and other information collection burdens imposed on the public.

The Service is requesting comments on Form 1099-C, which is used by credit unions and other financial institutions to report the cancellation or forgiveness of a debt of $600 or more. Credit unions and other financial institutions are required to report a discharge of indebtedness when one of eight specified identifiable events occurs. The form is used by the Service to verify compliance with the reporting rules and to verify that the debtor has included the proper amount of canceled debt in income on his or her income tax return.

Based on comments from credit unions, we believe Form 1099-C provides a clear and succinct format. The Service’s instructions are user-friendly and provide useful guidance for completing the form.

Thank you for the opportunity to express our views on the Service’s request for comment. If you have questions about our letter, please do not hesitate to call Senior Vice President and Deputy General Counsel Mary Dunn or me at 202-508-6733.

Sincerely,

Lilly Thomas
CUNA Assistant General Counsel