Looks good  to me.  Mark

 -----Original Message-----
From: 	Douglas, Stephen H.  
Sent:	Monday, October 22, 2001 4:04 PM
To:	Haedicke, Mark E.; Tawney, Mark
Subject:	Weather Derivatives Tax Position

Attached for your review is our position (prepared by me and Kevin Liss in the EWS Tax Department), to be presented by me on Thursday morning in Washington D.C., regarding expanding the category of hedgeable risks for U.S. tax purposes to include weather and other appropriate volumetric risks.  I will call you each to follow up.  SHD.

 << File: IRS Weather Derivative Submission.doc >>