May 23, 2016 VIA ELECTRONIC FILING
Internal Revenue Service P.O. Box 7604
Ben Franklin Station Washington, DC 20044
Definition of Political Subdivision, REG-129067-15: Submission of Comments and Request to Speak
Dear Sir or Madam:
On behalf of the American Public Gas Association (APGA), I hereby submit for filing the attached comments of APGA regarding the proposed regulations issued in the above-referenced docket.1
I also respectfully request permission for David Schryver, Executive Vice President of APGA, to speak on behalf of APGA at the public hearing scheduled for June 6, 2016, at 10:00 a.m. The following is the outline of the topics Mr. Schryver will discuss, along with the time to be devoted to each topic:
1. The nature and purpose of APGA: 1 minute.
2. The public services and public benefits that APGA members provide: 3 minutes.
3. How APGA members are governed as public entities: 3 minutes.
4. How the proposed regulations regarding the definition of “political subdivision” would adversely affect APGA members: 3 minutes.
Thank you for your consideration and assistance.
/s/ James R. Choukas-Bradley James R. Choukas-Bradley
Attorney for the American Public Gas Association
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