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					                                             American Trucking Associations

The American Trucking Associations submits the attached comments for
the consideration of the President's Advisory Panel on Federal Tax
Reform. We thank you for the opportunity to provide them.

Robert C. Pitcher

Vice President, State Laws

ATA

Alexandria, VA

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                            American Trucking Associations




          COMMENTS TO

THE PRESIDENT’S ADVISORY PANEL

   ON FEDERAL TAX REFORM

              BY THE

 AMERICAN TRUCKING ASSOCIATIONS


           March 31, 2005




                                          Robert C. Pitcher
                                 Vice President, State Laws
                            American Trucking Associations
                                            2200 Mill Road
                                    Alexandria, VA 22314
                                      Phone 703-838-7939
                             Email: bpitcher@trucking.org
                                                           American Trucking Associations



                                          March 31, 2005


The Honorable Connie Mack
Chairman
The President’s Advisory Panel on
 Federal Tax Reform
1440 New York Avenue, N.W.
Suite 2100
Washington, DC 20220

                        By email: comments@taxreformpanel.gov


Dear Senator Mack:

       These comments are made in response to the call for comments issued February

16, 2005, by the President’s Advisory Panel on Federal Tax Reform, specifically to the

first question posed by the Panel; that is, what are examples of:

       Headaches, unnecessary complexity, and burdens that taxpa yers – both
       individuals and businesses – face because of the existing system.

Our comments also address indirectly the Panel’s second and third questions, which

request “aspects of the tax system that are unfair,” and “examples of how the tax code

distorts important business or personal decisions.”

       ATA is the national trade association of the interstate trucking industry. It is a

united federation of motor carriers, 50 state trucking associations, and national trucking

conferences created to promote and protect the interests of the trucking industry. ATA's

direct dues-paying membership includes more than 2,000 trucking companies and

industry suppliers of truck equipment and services. Directly and through its affiliated

organizations, ATA represents over 34,000 companies of every size, type, and class of

motor carrier operation in the country.
                                                           American Trucking Associations



Page 2
Senator Connie Mack III
March 31, 2005

       Since the interstate trucking industry comprises more than half a million motor

carriers, some 96% of which operate 20 trucks or fewer, a great many of ATA’s members

are small businesses rather than large corporations. Many of these smaller operations are

subchapter S corporations or other pass-through entities for tax purposes. Their owners

are therefore interested in the Panel’s efforts from the point of view of individual as well

as business taxpayers.

       The Panel has posed the question: What are examples of “Headaches,

unnecessary complexity, and burdens that taxpayers - both individuals and businesses -

face because of the existing [federal tax] system.” ATA’s members tell us that the

following features of the Tax Code or its administration prove to be extremely

burdensome for them as both business and individual taxpayers:


        The alternative minimum tax for corporations;

        The alternative minimum tax for individuals;

        The phasing out and immediate reinstatement of the federal estate tax, which

           makes planning both difficult and necessarily short-term;

        The continual changes in and the complexity of the tax laws relating to

           defined-benefit pension plans;

        The continuing uncertainty over the proper structure and functioning of cash-

           balance pension plans;

        The continual changes in the depreciable lives for buildings;
                                                          American Trucking Associations


Page 3
Senator Connie Mack III
March 31, 2005


        The complexity of the tax treatment of foreign operations;

        Compliance with the broad requirements related to the disclosure of

          transactions “substantially similar” to listed transactions (such as loss

          transactions or transactions with significant differences between book and tax

          values); and

        The continued necessity for a motor carrier’s state of vehicle registration to

          rely on a hard-copy proof of payment of the federal heavy vehicle use tax,

          imposed under §§ 4041, ff.

       The American Trucking Associations appreciates the opportunity to offer

comments on these matters. We are following the Panel’s work with great interest.


                                     Sincerely,



                                     Robert C. Pitcher
                                     Vice President, State Laws

				
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