Andantech L.L.C., Wells Fargo Equipment Finance, Inc. (f.k.a. Norwest Equipment Finance, Inc.), Tax Matters Partner, and Wells Fargo & Co., A Partner Other Than the Tax Matters Partner, et al. - Page 77

                                        - 58 -                                          
               5.  Petitioners assert that a termination of Andantech-Foreign           
          occurred, see supra pp. 57-58, resulting in a deemed distribution             
          of partnership property to new and continuing partners (i.e., RD              
          Leasing and EICI) and that there was a deemed recontribution of the           
          property to a newly formed partnership.  Sec. 1.708-1(b)(1)(iv),              




























               18(...continued)                                                         
               Share of balloon notes ($19,990,512 x 98%)  19,590,702                   
               Share of term note ($87,429,319 x 98%)         85,680,733                
               Share of income                                85,191,494                
               Less                                                                     
               Share of term note Paid ($87,429,319 x 98%) (85,680,733)                 
               Share of withdrawal ($189,883 x 98%)           (186,085)                 
               Basis                                          119,488,123               

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