AXP STOCK FUND INC
NSAR-B, EX-99, 2000-11-28
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           Independent Auditors' Report on Internal Accounting Control

     The Board of Directors and Shareholders
     AXP Stock Fund, Inc.:


     In planning and  performing  our audits of the financial  statements of AXP
     Stock Fund,  Inc. for the year ended  September 30, 2000, we considered its
     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 Stock Fund, 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 Stock Fund,  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
     November 3, 2000




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