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The IRS Auditing Marriott International Inc.'s Federal Tax Returns
for Fiscal 2000 through 2002 Regarding $1 billion in Deductions
Related to Employee Stock Ownership Plan


Marriott International, Inc. (the "Company") disclosed, in its 2006 Annual Report on Form 10-K ("2006 Form 10-K"), that the Internal Revenue Service (the "IRS") is auditing the Company's federal tax returns for the 2000, 2001 and 2002 fiscal years. As part of that audit, the IRS is reviewing a leveraged employee stock ownership plan ("ESOP") feature of the Company's Employees' Profit Sharing, Retirement and Savings Plan and Trust (the "Plan") that was implemented in a transaction (the "ESOP Transaction") on June 13, 2000. Principal and interest on the debt related to the transaction was forgiven over a 26-month period as a mechanism for funding Company contributions of elective deferrals and matching contributions to the Plan. The Company claimed federal income tax deductions for the forgiven principal on the debt in the amount of $1 billion over that period, along with forgiven interest on the debt. The benefit related to the tax deductions was reflected in equity and did not flow through the provision for income taxes. 

On March 1, 2007, the Company received Notices of Proposed Adjustment from the IRS challenging most of the ESOP related federal income tax deductions claimed by the Company and proposing substantial excise taxes and penalties. We believe that the IRS' proposed adjustments are incorrect, intend to vigorously defend our positions and are examining various procedural alternatives for resolution of this matter. 





Also See: Lessons Learned From United's Employee Stock Ownership Plan / Dec 2002

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