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EXHIBIT 8
[CMS ENERGY CORPORATION LETTERHEAD]
June 21, 2000
Panhandle Eastern Pipe Line Company
5444 Westheimer Road
Houston, Texas 77056-5306
Ladies and Gentlemen:
Reference is made to the prospectus, (the "Prospectus"), which
constitutes part of the registration statement on Form S-4 (the "Registration
Statement"), to be filed by Panhandle Eastern Pipe Line Company with the
Securities and Exchange Commission on or about the date hereof pursuant to the
Securities Act of 1933, as amended, for the registration of 8.25% Senior Notes
Due 2010, Series B (the "Exchange Notes").
I am of the opinion that the statements set forth under the
caption "Certain United States Federal Income Tax Consequences" in the
Prospectus constitute an accurate description, in general terms, of certain
United States federal income tax consideration that may be relevant to the
prospective holders of the Exchange Notes.
I hereby consent to the filing of this opinion as an exhibit
to the Registration Statement.
Very truly yours,
/s/ Jay M. Silverman
Principal Tax Attorney
