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Name of First Tier First Tier
Partnership TIN Years
Federal Arbitrage 13-2964750 1978-1988
NOW IT IS HEREBY DETERMINED AND AGREED for Federal
income tax purposes that:
1. In each year they had an interest in the
partnerships, the taxpayers will recognize their
distributive share of the partnerships' net trading
gain or loss from the Arbitrage Management securities
trading transactions. The net trading gain or loss
equals the annual increase or reduction in the
taxpayers' K-1 capital account, plus any capital
distributions received from the partnerships during the
year. The taxpayers will recognize income to the
extent of such capital distribution.
* * * * * * *
7. In accordance with paragraphs 1 through 6,
the attached TABLE 1, which is incorporated into this
agreement by this reference, represents all of the
taxpayers' taxable income, deductions, gains and losses
from their interest in the partnerships.
8. The annual tax underpayments and overpayments
attributable to the taxpayers' interest in the
partnership shall be calculated by comparing the
amounts in TABLE 1 to the partnerships items reported
by the taxpayer(s) on their original returns. * * *
* * * * * * *
10. Other than as provided in paragraph 8, no
additions to the tax or penalties shall be imposed with
respect to the taxpayers' interest in the partnership,
including the additions and penalties described in
I.R.C. Section 6653, 6659, and 6661.
* * * * * * *
13. The taxpayers' taxable income for any taxable year
shall not be increased at any time after the execution of
this agreement due to the taxpayers' interest in the
partnerships, except to the extent that the taxpayer receive
actual distributions of cash and/or property from the
partnerships after the execution of this agreement.
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Last modified: May 25, 2011