AXP VARIABLE PORTFOLIO INCOME SERIES INC
NSAR-B, EX-99, 2000-10-27
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           Independent Auditors' Report on Internal Accounting Control



The Board of Directors and Shareholders AXP Variable Portfolio -- Income Series,
Inc.:


In planning and  performing  our audits of the financial  statements of AXP VP--
Federal Income Fund (fund within AXP Variable Portfolio -- Income Series,  Inc.)
for the period  from  September  15, 1999 (date the fund  became  available)  to
August 31, 2000 and AXP VP -- Bond Fund, AXP VP -- Extra Income Fund, and AXP VP
-- Global Bond Fund,  (funds  within AXP Variable  Portfolio  -- Income  Series,
Inc.) for the year ended August 31, 2000, we considered their internal  control,
including control activities for safeguarding securities,  in order to determine
our  auditing  procedures  for the  purpose  of  expressing  our  opinion on the
financial  statements and to comply with the  requirements of Form N-SAR, not to
provide assurance on the internal control.

The management of AXP Variable  Portfolio -- Income Series,  Inc. is responsible
for  establishing  and  maintaining   internal   control.   In  fulfilling  this
responsibility, estimates and judgments by management are required to assess the
expected  benefits and related costs of controls.  Generally,  controls that are
relevant to an audit  pertain to the entity's  objective of preparing  financial
statements for external  purposes that are fairly  presented in conformity  with
generally   accepted   accounting   principles.   Those  controls   include  the
safeguarding of assets against unauthorized acquisition, use or disposition.

Because of inherent  limitations in internal  control,  errors or irregularities
may occur and not be detected.  Also,  projection of any  evaluation of internal
control to future  periods is subject to the risk that it may become  inadequate
because of changes in  conditions  or that the  effectiveness  of the design and
operation may deteriorate.

Our  consideration  of the internal  control would not necessarily  disclose all
matters  in the  internal  control  that  might  be  material  weaknesses  under
standards established by the American Institute of Certified Public Accountants.
A material  weakness is a condition  in which the design or  operation of one or
more of the internal  control  components  does not reduce to a  relatively  low
level the risk that misstatements caused by error or fraud in amounts that would
be material in relation to the financial  statements being audited may occur and
not be detected  within a timely  period by  employees  in the normal  course of
performing their assigned functions.  However, we noted no matters involving the
internal  control  and  its  operation,   including  controls  for  safeguarding
securities, that we consider to be a material weakness as defined above.

This report is intended solely for the  information  and use of management,  the
Board of Directors of AXP Variable  Portfolio -- Income  Series,  Inc.,  and the
Securities  and Exchange  Commission and is not intended to be and should not be
used by anyone other than these specified parties.




KPMG LLP




Minneapolis, Minnesota
October 6, 2000



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