----- Forwarded by Sue Nord/NA/Enron on 01/05/2001 12:20 PM -----

	"Daniel Clearfield" <dclearfield@wolfblock.com>
	01/05/2001 10:32 AM
		 
		 To: <Sue_Nord@enron.com>
		 cc: 
		 Subject: Fwd: Re: Set Up LLC for CLEC Activity

Here's the answer to your question of earlier in the week.  Best regards.

Daniel Clearfield, Esq.
Wolf, Block, Schorr and Solis-Cohen LLP
212 Locust St., Suite 200
Harrisburg, PA  17101
(717) 237-7173
(717) 237-7161 fax


----- Message from on -----

In response to the question by Enron, the state PUC will accept partnership 
tax return information for a LLC.  The state PUC follows whatever the 
Department of Revenue requires to be utilized.  Accordingly, where an LLC is 
treated for federal income tax purposes as a partnership are tax classified 
as a partnership for Pennsylvania purposes under the normal Personal Income 
Tax provisions but are still treated as a corporation for Capital 
Stock/Franchise Tax purposes.  The LLC partnership would therefore be able to 
file a PA-65 form which is based on the Federal 1065 partnership return with 
the Department of Revenue and the PUC.

DAN