Bernard William Hvidding and Faleasiu E. Hvidding - Page 4

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          passed through to petitioner would be reported on a schedule K-1;           
          (5) the HEH trustees would pass through to petitioner State tax             
          credits of $1,750 and Federal tax credits of $575; and (6)                  
          petitioner is liable for all energy payments regardless of                  
          whether any tax credits are passed through to him.  Petitioner              
          received a beneficiary certificate dated December 31, 1996, which           
          stated that Federal energy tax credits could be allocated to him            
          at the discretion of the trustees of HEH.                                   
               On the day petitioner entered into the SEP agreement,                  
          petitioner and HEH jointly applied for a copayment from Hawaiian            
          Electric Company, Inc. (HELCO), the local public electric                   
          provider.  HELCO offered the $800 rebate under a program intended           
          to promote the use of solar energy for heating water.  HELCO paid           
          HEH $800 after April 4, 1997, when a Mercury Solar representative           
          certified that Mercury Solar had installed the solar heating                
          system in petitioners’ home in accordance with the HELCO rebate             
          program specifications.                                                     
               Around the time petitioner and HEH entered into the SEP                
          agreement, HEH agreed to pay Mercury Solar $6,125 to install the            
          solar system on petitioners’ roof.  HEH agreed to pay a $4,625              
          downpayment less an $800 electric rebate when work was started,             
          and $1,500 when work was finished.                                          
               Shortly after petitioner and HEH entered into the SEP                  
          agreement, petitioner signed an Option to Extend Term/Option to             






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