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Enron Mail |
Let's set something up for monday
-----Original Message----- From: Burden, Bill M [mailto:BurdenBM@bp.com] Sent: Friday, October 19, 2001 12:52 PM To: Fuller, Dave; Barry, Penny Cc: Burden, Bill M; Colburn, Kim W; Miller, Tim; Whitt, Mark; Miller, Stephanie Subject: RE: Income Tax Issue Dave, Our tax folks would like to talk to your accountants - is there a name and phone number contact where we can arrange a call for the experts to talk it through? -----Original Message----- From: Fuller, Dave [mailto:Dave.Fuller@enron.com] Sent: Friday, October 19, 2001 1:12 PM To: barryp@bp.com Cc: BurdenBM@bp.com; ColburKW@bp.com; millertr@bp.com; Whitt, Mark; Miller, Stephanie Subject: Income Tax Issue Hello Penny, It was nice meeting you and your associates yesterday. I presented the income tax issue that we discussed to some of our accountants and they see things a little differently. It is our opinion, that since a cash payment would be offset by the demand charge obligations associated with the capacity contract, it is not income per se, but rather funds dedicated to meeting an out-of-the-money contract obligation. Depending on your accounting method, that money would probably be amortized over the term of the contract. Let me know what you think, perhaps we should have our accountants talk. As for adjusting the cash amount after the San Juan/Permian allocation issue is settled (I'm not sure you could hear all that at your end of the table) we are not really interested in any type of post assignment "true-ups". But we are willing to talk about what those allocation percentages should be. Regarding next steps, on Monday I will provide you with some "alternative" forms of payment and some ways we might spread the payments out0. After that we will look to you guys for your preferred deal structure and payment terms. I'll follow up this email with a phone call today. Dave Fuller Enron North America 503-464-3732 ********************************************************************** This e-mail is the property of Enron Corp. and/or its relevant affiliate and may contain confidential and privileged material for the sole use of the intended recipient (s). Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender or reply to Enron Corp. at enron.messaging.administration@enron.com and delete all copies of the message. This e-mail (and any attachments hereto) are not intended to be an offer (or an acceptance) and do not create or evidence a binding and enforceable contract between Enron Corp. (or any of its affiliates) and the intended recipient or any other party, and may not be relied on by anyone as the basis of a contract by estoppel or otherwise. Thank you. **********************************************************************
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