Black & Decker Decker 701 701 East Joppa Road Towson, MD 21286 410.716.3900 www. bla cka nd de eke r. co m www.blackanddecker.com
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LEDER LETTER OF OFCOMMENT COMMENTNO. NO.\ \ & 5
Mr. Robert H. Herz Chairman, Financial Accounting Standards Standards Board Chairman, 401 Merrill Merritt 7 401 Box5116 P.O. Box 5116 Norwalk, CT 06856-5116
FEN48 48 RE: Delay in Effective Date of FIN Chairman Herz: Dear Chairman Corporation, we strongly urge the Financial Accounting On behalf of The Black & Decker Corporation, Board to delay the effective date date of FIN FIN 48 48 on on Accounting for Uncertainty in Income Standards Board substantive, procedural, and Taxes to allow companies sufficient time to address the substantive, posed by the new interpretation. interpretation. Specifically, we recommend that the documentation challenges posed FIN 48 be deferred to fiscal years beginning after December 15, 15, 2007. The effective date of FIN FIN 48 were articulated by Tax Executives Executives Institute in in a leller letter it sent challenges of implementing FIN to you on December 12, 2006. In summary, extending the deadline for implementing FIN FIN 48 will permit companies and their independent independent auditors to resolve resolve unanswered unanswered questions and and thus reduce reduce the likelihood of diversity in practice, which in part prompted the development of FIN 48 in the first instance. instance.
Respectfully,
*—v Michael D. Mangan Senior Vice President and Chief Financial
Christina M. McMullen Vice President and Controller
*
decker - FASB
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Black & Decker Decker 701 701 East Joppa Road Towson, MD 21286 410.716.3900 www. bla cka nd de eke r. co m www.blackanddecker...