Estate of Donald H. Ray, Deceased, Patricia G. Ray, Independent Executrix, and Patricia G. Ray - Page 4

               RDB was a partner of Valley Cable, Ltd. (Valley Cable), a              
          Texas limited partnership, and Valley Cable was subject to the              
          unified audit and litigation procedures set forth in sections               
          6221 through 6233 (the TEFRA provisions) enacted by the Tax                 
          Equity and Fiscal Responsibility Act of 1982, Pub. L. 97-248,               
          sec. 402(a), 96 Stat. 648, and amended retroactively by the                 
          Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 714(p)(1), 98           
          Stat. 494, 964.  RDB was a pass-thru partner as defined in                  
          section 6231(a)(9).  Mr. Ray, Mrs. Dominguez, and Breese were               
          indirect partners of Valley Cable, as defined in section                    
          6231(a)(10), due to their ownership interest in RDB.                        
               In 1984, Mr. Ray, Mrs. Dominguez, and Breese were partners             
          in 6121 Joint Venture (6121), a general partnership, and RDB                
          transferred its interest in Valley Cable to 6121.  R.D.B.                   
          Investments II, Inc., was not a partner in Valley Cable during              
          the taxable years 1983 or 1984, and all references to R.D.B.                
          Investments II, Inc., refer to RDB with respect to the taxable              
          year 1983 and refer to 6121 with respect to the taxable year                
          1984.  All actions taken in the name of R.D.B. Investments II,              
          Inc., were intended to be treated as the actions of RDB and 6121            
          with respect to the taxable years 1983 and 1984, respectively.              
          For convenience, we will refer to RDB, 6121, and R.D.B.                     
          Investments II, Inc., as RDB.                                               
               Respondent designated Valley Cable a litigation project case           
          and assigned Valley Cable to a litigation project referred to as            

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