Dakotah Hills Offices Limited Partnership, An Arizona Limited Partnership, William M. and Dianne B. Stephens, Tax Matters Partners, et al. - Page 16

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                  the partnerships for federal income tax purposes,                   
                  provided that a reasonable basis exists for that                    
                  return position.                                                    
                       In the event that the Internal Revenue                         
                  Service declines to issue a determination letter                    
                  or ruling on the abandonment issue or Investors’                    
                  attorneys withdraw the request after mutual                         
                  agreement with the Trustee, the Trustee may file                    
                  a motion pursuant to 11 U.S.C. � 505 (b) for a                      
                  prompt audit of the partnerships’ tax returns.                      

             Ultimately, the trustee entered into the agreement with the              
             investors, and the agreement was approved by the Bankruptcy              
             Court.  The record does not disclose what action, if any,                
             was taken to seek a ruling from the Internal Revenue                     
             Service as contemplated in the passages of the agreement,                
             quoted above, or what action, if any, was taken by the                   
             Internal Revenue Service.                                                
                  The Form 1065, U.S. Partnership Return of Income,                   
             filed on behalf of Dakotah Hills for calendar year 1989                  
             includes balance sheets as of the beginning and end of the               
             year on Schedule L.  Line 5 of Schedule L includes the                   
             following “Other current assets”:                                        

                                            Beginning     Ending                     
             Notes receivable--investors  $192,400     $192,400                       

             Line 12 of Schedule L includes the following “Other                      
             assets”:                                                                 
                                           Beginning       Ending                     





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