Donald A. Robins - Page 4

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          percent of the convent property was to be donated in 1985 and the           
          remainder in 1986.                                                          
               The Memorandum outlined the tax benefits and the tax risks             
          to investors attributable to the donation of the convent                    
          property.  The Memorandum explained that:                                   
               The Partnership has engaged an independent real estate                 
               appraiser to determine the fair market value of the                    
               convent building.  His appraisal is not expected to be                 
               completed before this offering closes.  The value of                   
               the proposed gift is a question of fact, and there can                 
               be no assurance that, if the Partnership is audited by                 
               the Internal Revenue Service, such value will be                       
               accepted.  The Internal Revenue Service may engage on                  
               its own an independent appraiser to value the                          
               charitable gift, and it is possible that the Service                   
               will arrive at a different value.  The Partnership may                 
               have to resort to litigation to settle the issue.                      
          The Memorandum repeatedly cautioned that the Internal Revenue               
          Service might challenge the valuation of the convent property.              
               In a section entitled "Risk Factors", the Memorandum warned            
          that:                                                                       
                    There can be no assurance that the value the                      
               Partnership will claim for the charitable deduction                    
               will be accepted by the Internal Revenue Service in the                
               event of an audit of the Partnership's tax return.  If                 
               the valuation is contested and a lower valuation                       
               results, the Partnership (and, hence, each Partner),                   
               will have disallowed, to that extent, a portion of its                 
               charitable deduction. * * * along with the assessment                  
               of interest on the deficiency and also the possible                    
               assessment of penalties, including the substantial                     
               overvaluation penalty (see Tax Aspects) which is equal                 
               to 30% of the deficiency in tax caused by the                          
               overvaluation.                                                         
               In the subsection "Additions to Tax - Penalties & Interest",           
          the Memorandum explained in detail that the substantial                     





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