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. Respectfully submitted, /s/ James R. Choukas-Bradley James R. Choukas-Bradley Attorney for the American Public Gas Association
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