1 2 1 5 - U 0 1 *
OF COMMENT NO. \ LETTER OF
Barr Pharmaceuticals, Pharmaceuticals, Inc. Inc. 400 Chestnut Ridge Ridge Road Woodcliff Lake, Lake, NJ 07677 Woodcliff Mr. Robert H Herz Chairman, Financial Accounting Accounting Standards Board 401 401 Merritt Merritt 7 PO Box5116 Box 51 16 Norwatk.CT 06856-51 16 Norwalk, CT 06856-5116 Dear Herz: Dear Chairman Herz; On behalf of Barr Pharmaceuticals, Pharmaceuticals, Inc., I strongly urge the the Financial Accounting Standards Board Board to delay the effective date of FIN FIN 48 on Accounting for Uncertainty in Income Taxes to allow companies sufficient sufficient time to address the substantive, procedural, procedural, and documentation documentation challenges posed by by the new interpretation. Specifically, I recommend that the effective date of FIN FIN 48 be be deferred to fiscal years beginning after December 15, 15, 2007. The challenges of implementing implementing FIN FIN 48 were articulated by Tax Executives Institute in a letter letter it sent to you on December December 12, 12, 2006. In summary, extending the deadline deadline for implementing FIN FIN 48 will permit companies companies and their independent auditors to resolve unanswered questions and thus reduce the likelihood of diversity diversity in practice, which which in part prompted the development of FIN FIN 48 in in the first instance. Respectfully,
Rocco Rositano, Vice President of Taxation Taxation Barr Pharmaceuticals, Inc.