FYI

 -----Original Message-----
From: 	Cilia, Mary  
Sent:	Wednesday, September 26, 2001 2:45 PM
To:	Hayslett, Rod; Goodrow, Alicia; Bowes, Bill
Cc:	Patrick, Michael K.; Coulter, Jodi; Pernot, Catherine
Subject:	EOTT Gain Calculation

Based on discussions with Bill, there are deferred taxes already recorded on the books for the difference between the book basis and the tax basis in the common units, sub units and APIs.  Therefore, there is no punitive tax expense created in the 3rd quarter by executing the 140 transaction.  The book tax calculations will be just the effective tax rate (approximately 37%) multiplied by the pre-tax book gain.  Accordingly, the tax expense will not result in a non-recurring loss on the sale.  The net gain will be approximately $6 million prior to the effects of the EGM MTM income.  Let me know if you have any questions.  Thanks.

Mary