Sheldon M. Sisson - Page 4

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               Mr. Schulman promoted the partnerships by representing that            
          each limited partnership interest would be entitled to an                   
          interest deduction in the first year equal to the partner's cash            
          capital contributions.  The purported interest deductions for the           
          first year were generated through a circular transfer of funds              
          among several entities, including foreign entities in Panama and            
          the Netherlands Antilles.  The transactions occurred between                
          December of 1982 and December of 1983.                                      
               On August 22, 1983, the IRS and Mr. Schulman executed a                
          preliminary agreement entitled "SETTLEMENT PLAN AGREEMENT".  The            
          agreement's "RECITALS" section stated:                                      
                                                                                     
                              2.1  IRS is presently auditing                          
               SCHULMAN'S individual tax returns (IRS Form 1040) for                  
               the years 1977 through 1982.  Additionally, IRS intends                
               to audit SCHULMAN'S 1983 individual tax return (IRS                    
               Form 1040).                                                            
               *        *        *        *        *        *        *                
                              2.4  IRS and SCHULMAN desire to amicably                
               settle all questions relating to SCHULMAN'S individual                 
               tax returns and the deductions taken by the investors                  
               in connection with their investment in the SCHULMAN                    
               Partnerships. * * *                                                    
                              2.5  This document is intended to be an                 
               agreement in principle establishing the concepts upon                  
               which a formal settlement agreement will be drafted.                   
               Both the IRS and SCHULMAN shall exercise the utmost                    
               good faith in attempting to achieve the final                          
               settlement of the matters described herein.                            
               Nevertheless, SCHULMAN and the IRS acknowledge that the                
               concepts established hereunder may result in unforeseen                
               consequences which may render settlement impossible.                   







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