Independent Auditors' Report
on Internal Accounting Control
The Board of Directors and Shareholders
AXP Utilities Income Fund Inc.:
In planning and performing our audits of the financial statements of
AXP Utilities Income Fund, Inc. for the year ended June 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 Utilities Income 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 errors or irregularities 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 Utilities Income
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
August 4, 1999
