First Blood Associates, Richard M. Greenberg, Tax Matters Partner, et al. - Page 6

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               After receiving Mr. Long's letter, Mr. Faber contacted Mr.             
          Long to discuss whether investment tax credits would be allowed             
          under the settlement offer outlined in his letter.  In response             
          to this query, Mr. Long followed up with a letter dated November            
          1, 1990, to Mr. Faber.  This letter stated in relevant part:                
                    By letter dated August 6, 1990, we extended an offer to           
               settle the above mentioned movie partnerships.  We offered             
               to settle these cases on the basis of and[sic] I.R.C. [sec.]           
               465 "at risk" settlement. * * *                                        
                    We originally requested that you accept, or reject, the           
               offer to settle by September 28, 1990. * * * Since we were             
               unable to respond to your question within a reasonable time            
               before the September 28, 1990, deadline, we advised you that           
               we would tender a subsequent offer to you which would                  
               address the investment tax credit issue.                               
                    The purpose of this letter is to extend a new offer to            
               settle these cases on the basis of an "at risk" settlement             
               under I.R.C. [sec.] 465.                                               
          In closing, Mr. Long wrote:  "This offer is open for fourty-                
          five[sic] days, after the date of this letter."  Mr. Faber                  
          rejected this settlement offer on behalf of the partners.                   
               After the filing of the petitions in docket Nos. 623-92,               
          13014-92, and 15641-92 Mr. Long again wrote to Mr. Faber on the             
          subject of the Greenberg Brothers project, listing First Blood in           
          the subject portion of the letter.  The letter dated September 9,           
          1992, stated:                                                               
               We are offering to settle the above referenced movie tax               
               shelters on the basis of an "at risk" settlement under                 
               I.R.C. [sec.] 465.  For purposes of the settlement taxpayers           
               are considered at risk to the extent of their initial cash             
               investment in the movie, with no amounts allowed for notes             
               executed by the partnership, or the assumption agreement               

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