Untitled Document

Initial Letter Date

Form filed

Market Capitalization

04/12/2012

10-K

$ 9,270 M

We note from the discussion on page [xx] that during 2011, the company recognized a $[xx] million benefit in income from discontinued operations that was driven by the reversal of tax amounts reserved in prior years related to the divestiture of the company's [xx] subsidiaries. We also note that the amounts had been reserved pending resolution with the IRS on the treatment of the transaction. Please tell us and revise the notes to your financial statements to explain in further detail the nature and timing of the facts or circumstances that resulted in the company establishing these tax reserves in prior periods. Also, please tell us and revise the notes to your financial statements to explain in further detail that nature and timing of the changes in facts or circumstances that caused the company to eliminate these tax reserves during 2011.