G. Dastgir and Mary A. Qureshi - Page 7

                                         -7-                                          
               WHEREAS, a dispute has arisen between the parties as to                
               the amount of the taxpayers’ income, gains, losses,                    
               credits, and deductions related to investments and                     
               transactions with FoodSource, Inc.; and                                
               WHEREAS, the parties wish to determine with finality the               
               taxpayers’ income, gains, losses [,] credits, and                      
               deductions for the taxable years [ending] December 31,                 
               1979, December 31, 1980, December 31, 1982 and December                
               31, 1983 with respect to investments and transactions                  
               with FoodSource, Inc.                                                  
               NOW IT IS HEREBY DETERMINED and AGREED for Federal Income              
               Tax purposes that:                                                     
                    (1) No item of income, gain, loss, credit,                        
                    and deduction from the taxpayers’ transactions                    
                    and investments with respect to FoodSource,                       
                    Inc. is recognized with regard to container                       
                    #506622, which was considered to be placed in                     
                    service December 5, 1983.                                         
                    (2) No depreciable basis shall be allowed for                     
                    the container.                                                    
                    (3) No investment tax credit shall be allowed                     
                    for the container.                                                
                    (4) Any interest paid on the note financing                       
                    the purchased container from FoodSource, Inc.                     
                    would not be allowed as a deduction in any                        
                    year.                                                             
                    (5) No maintenance,  insurance,  or  other                        
                    operating expenses would be allowed to the                        
                    extent cash payments were paid for them,                          
                    unless a portion of the container income                          
                    reported was used to offset the expense.                          
                    (6) Overvaluation and negligence penalties                        
                    are determined to be NONE and NONE for the                        
                    year 1979, NONE and NONE for the year 1980,                       
                    NONE and NONE for the year 1982, and $2,154.30                    
                    and NONE for the year 1983, respectively.                         
                    (7) Any future receipt by the taxpayers of                        
                    damages or monies from FoodSource or its                          
                    related entities and agents shall be included                     





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