Dakotah Hills Offices Limited Partnership, An Arizona Limited Partnership, William M. and Dianne B. Stephens, Tax Matters Partners, et al. - Page 4

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                  For purposes of our consideration of Petitioners’                   
             Motion for Summary Judgment, the parties have not presented              
             to the Court all of the documents that are pertinent to                  
             each of the nine cases.  They have attached as exhibits to               
             the stipulation several categories of documents that relate              
             to each petitioner.  These include the partnership agree-                
             ment for each partnership, the U.S. Partnership Return of                
             Income filed on Form 1065 by each partnership for taxable                
             year ending December 31, 1989, and the FPAA issued by                    
             respondent to each partnership.  They have also attached as              
             exhibits to the stipulation certain other documents that                 
             relate to one of the partnerships, Dakotah Hills Offices                 
             Limited Partnership, in the case of docket No. 18955-93                  
             (Dakotah Hills).  As we read the Stipulation of Facts, the               
             parties intend the Dakotah Hills documents as exemplars of               
             the documents executed with respect to all of the cases.                 
             In the following discussion, we have focused on the facts                
             in the Dakotah Hills case, and references to the partner-                
             ship are references to Dakotah Hills.                                    
                  Dakotah Hills was formed by a group of four general                 
             partners, Mr. David Randall Jenkins, Ms. Renee Jenkins,                  
             Mr. Timothy Lee Shaftel, and the JNC Companies, an                       
             Arizona corporation.  It was established on or about                     
             October 25, 1984, pursuant to the Uniform Limited                        
             Partnership Act of the State of Arizona, when the Agreement              




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