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EA 83-XII paid loan origination fees to EMI in the
aggregate amount of $148,246 equal to 4 percent of the
principal amount of the first mortgage loans (i.e.,
$3,706,150 x 4 percent). This amount was amortized over
the life of the loans. For each of the years in issue,
EA 83-XII reported "points amortization" expense of $16,671
on each of the subject returns.
EA 84-III
EPIC formed EA 84-III on September 14, 1983, pursuant
to the Uniform Limited Partnership Act of the Commonwealth
of Virginia for a 10-year term ending on September 14,
1993. EPIC was the sole general partner. The Certificate
and Agreement of Limited Partnership was amended by the
execution and filing of an Amended and Restated Certificate
and Agreement of Limited Partnership dated October 1, 1983,
which was recorded on December 20, 1983, among the limited
partnership records maintained by the clerk of the court of
Fairfax County, Virginia. The Certificate and Agreement of
Limited Partnership of EA 84-III was amended for a second
time on April 1, 1985. The Second Amended and Restated
Certificate and Agreement of Limited Partnership (84
partnership agreement) describes the business of EA 84-III
in the following terms:
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