First Blood Associates, Richard M. Greenberg, Tax Matters Partner, et al. - Page 8

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                    Even if you do not wish to settle First Blood                     
               Associates for all years, we still intend to concede 1982.             
               We, therefore, request that you return the enclosed document           
               at your earliest convenience.                                          
          The "at risk" terms were similar to those outlined in the                   
          September 9, 1992, letter to Mr. Faber.                                     
               Although the September 14, 1992, letter was addressed to Mr.           
          Redding, it was inadvertently mailed to Mr. Faber.  Mr. Faber               
          forwarded the letter to the Goodwins at their home in Montgomery,           
          Texas.  Upon receiving the letter on or about October 1, 1992,              
          Mr. Goodwin contacted Mr. Redding to arrange a meeting to discuss           
          its contents.  The two eventually met at Mr. Redding's office on            
          October 12, 1992, at which time Mr. Goodwin instructed Mr.                  
          Redding to accept the settlement offer extended in Mr. Long's               
               During this period of the settlement negotiations, and                 
          subsequently, Mr. Long understood that either a closing agreement           
          or a Form 870 would be used, and Mr. Faber understood that to               
          effectuate a settlement some documents would have to be executed.           
          Mr. Redding had been in contact with Messrs. Faber and Long.                
               In a letter to Mr. Long dated October 14, 1992, Mr. Redding            
          stated that he was accepting the settlement offer on behalf of              
          the Goodwins and wrote:  "I would appreciate it if you would                
          confirm to me that you are in receipt of a timely acceptance of             
          your settlement offer."  There is no indication that the executed           

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