Dear Gerald:  I called Judy Thorn, ENA Upstream staff.  She said that as far as tax matters went, she wasn't sure who set up the structure for the company.  She said, however, that she'd had dealings with Chris Bystriansky in the tax department about the severance taxes.  He shows up as a senior tax analyst at ext. 53040.  Is he the person who called you? If not, maybe he'll have the answer your tax contact requested.   --MCO