Agri-Cal Venture Associates, Frederick H. Behrens, Tax Matters Partner, et al. - Page 20




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          determined to have been a general partner in the partnership for            
          Federal income tax purposes when the AVA 1984 Form 1065 was                 
          signed by Mr. Voyer, on February 1, 1985, then such return is               
          valid.  We must, thus, determine whether AMCOR was a partner in             
          the partnership on February 1, 1985.                                        
                    c.  California Revised Limited Partnership Act; AVA               
                         Limited Partnership Agreement                                
               CRLPA section 15641 provides as follows:                               
               �15641.  Admission of additional general partners                      
                    Unless otherwise provided in the partnership                      
               agreement, after the filing of a certificate referred                  
               to in Section 15621, a general partner may be admitted                 
               only (a) with the written consent of each general                      
               partner and such affirmative vote of limited partners                  
               as is required in accordance with the provisions of                    
               subdivision (f) of Section 15636 and the last paragraph                
               of Section 15636 or (b) with the written consent of                    
               each partner in accordance with the provisions of                      
               subdivision (c) of Section 15681.                                      
          Cal. Corp. Code sec. 15641 (West 1991).                                     
               As set forth supra in section III.A.2, section 11.1.e of the           
          AVA limited partnership agreement accorded to the general                   
          partners the “right and authority, without the requirement of               
          obtaining the approval or consent of the Limited Partners, to               
          admit an additional Co-General Partner to the Partnership”.  The            
          agreement, therefore, provided an alternative to the otherwise              
          mandatory provisions of CRLPA section 15641 (requiring some form            
          of assent by the limited partners).  Pursuant to CRLPA section              








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