Agri-Cal Venture Associates, Frederick H. Behrens, Tax Matters Partner, et al. - Page 16




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          signed “Joseph O. Voyer Treasurer”.  It shows the date of that              
          signature as February 1, 1985.  It does not state the                       
          organization, if any, of which Joseph O. Voyer was treasurer.               
          The partnership never had a treasurer; Mr. Voyer was never a                
          partner in the partnership.  Mr. Voyer was an officer and                   
          employee of AMCOR.                                                          
               Neither the AVA 1984 or 1985 Forms 1065 designates any                 
          partner as the TMP of the partnership.                                      
                    5.  Designation of TMP                                            
               In 1988, Deborah R. Gaither, a revenue agent employed by               
          respondent, was conducting an examination of various AMCOR                  
          sponsored partnerships.  In September 1988, Ms. Gaither prepared            
          a letter for signature by Messrs. Behrens and Schreiber, which              
          she carried to Messrs. Behrens and Schreiber, who signed the                
          letter on September 30, 1988 (the September 30 letter), and                 
          immediately returned it to her.  Pertinent portions of the                  
          September 30 letter follow:                                                 
               Sept. 30, 1988                                                         
               Internal Revenue Service                                               
               24000 Avila Road                                                       
               Laguna Niguel, California 92677                                        
               RE:  TAX MATTERS PARTNER                                               
               Gentlemen:                                                             










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