text_combined: fw tax reserve allegheny peakers spoke matthew explained transaction tax reserve calculation summary attached prepared communicated deal group early last fall calculation indicates aggregate transaction tax exposure including penalties 12 940 182 initial suggested tax reserve related exposure approximately 1 2 amount discussions last week increased 100 percent thus increase tax reserve approximately 6 000 000 thus evident calculation incorrect assessment probability increased thus suggested tax reserve changed matthew influenced increasing applicable level risk related transaction desire conservatively posture enron completion disposition insure subsequent period surprises occur obviously extent collective management belief conservative posture appropriate tax reserve amount may reduced matthew spoke change proposed impression comfortable change made ultimately realize reserved amount earnings risk tax planning strategies subsides matthew back office may 8 ready speak whomever desires time attending enron law conference beginning afternoon followed enron industrial markets offsite next monday tuesday reached cell phone 713 817 5052 best regards steve original message kitchen louise sent tuesday may 01 2001 5 55 pm douglas stephen h cc colwell wes miller hou ect enron subject fw tax reserve allegheny peakers substantial difference requested deal done waiting matthew return explain opinion changed concerned making change got wrong start rather change stephen h douglas enron enronxgate 05 01 2001 12 07 pm wes colwell enron enronxgate cc louise kitchen hou ect ect subject fw tax reserve allegheny peakers wes attached explanation allegheny tax reserve know increased understanding reserve quantified matt gockerman group requested time ago commercial leads aware may coming across increase reality simply properly booking currently previously expected said differently without disposition would spread tax time disposition became necessary accelerate reflected tax reserve always asked absolutely necessary amount reserved please call ext 30938 discuss matter best regards steve original message douglas stephen h sent monday april 30 2001 8 32 pm kitchen louise subject tax reserve allegheny peakers reserve referred relates sales use tax sales use tax liability related purchase use peaker project companies various equipment e turbines illinois transformers tennessee indiana used construct peaker facilities illinois indiana tennessee enron bears tax obligation sales agreement pursuant sold peakers allegheny effectively tax liability pre acquisition date tax liability seller responsible typically equipment used construct peakers would assessed sales use tax purchased project company built respective peaker tax would effectively passed buyer sale allegheny ews tax department structured acquisition respective equipment either avoid sales use tax spread cost tax time example sales leaseback strategy employed illinois spread cost sales use tax many years lease payments made rather pay front ultimately benefitted since use much cash constructing peakers earned disposition peakers otherwise would since counterparty would believe specific case allegheny modelled cost peakers including full current payment sales use tax said requested portion disposition proceeds sale peakers reserved applicable statute limitations related types strategies employed achieve described results expires since risk position could challenged challenged risk would prevail matt may 8 recent father baby girl upon return available discuss matter whomever would like matt worked closely others generation asset group assured suggested reserve sound overly conservative liberal position best regards steve original message kitchen louise sent monday april 30 2001 3 18 pm matthew f gockerman hou ect enron cc stephen h douglas hou ect enron miller hou ect enron subject tax reserve allegheny peakers notice gain substantially decreased due tax reserve increase 5 added recently regards louise