Marianne Hopkins - Page 5

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                         5.  The Taxpayers are not entitled to any                    
                    deductions in the taxable year ending December 31,                
                    1981, or in any subsequent year, other than the                   
                    deductions which are set forth in paragraphs “1”                  
                    and “2” above.                                                    
                         6.  Any release, discharge or forgiveness of                 
                    any obligation with respect to the Taxpayers’                     
                    investment in the Partnership in any year                         
                    subsequent to the taxable year ending December 31,                
                    1981 will not result in gross income to the                       
                    Taxpayers in any taxable year.                                    
                         7.  No penalty shall be assessed against the                 
                    Taxpayers for the taxable year ended December 31,                 
                    1981 or any subsequent taxable year by reason of                  
                    the disallowance of any losses claimed as a result                
                    of their interest in the Partnership.  The                        
                    increased interest rate pursuant to I.R.C. �                      
                    6621(c) shall apply.                                              
               This agreement is final and conclusive except:                         
                    (1) the matter it relates to may be reopened in                   
                         the event of fraud, malfeasance, or                          
                         misrepresentation of material fact;                          
                    (2) it is subject to the Internal Revenue Code                    
                         sections that expressly provide that effect                  
                         be given to their provisions notwithstanding                 
                         any other law or rule of law except Code                     
                         section 7122; and                                            
                    (3) if it relates to a tax period ending after                    
                         the date of this agreement, it is subject to                 
                         any law, enacted after the agreement date,                   
                         that applies to that tax period.                             
                    By signing, the above parties certify that they                   
               have read and agreed to the terms of this document.                    
          Respondent accepted the closing agreement on October 13, 1988.              
               Respondent made adjustments to petitioner and Mr. Hopkins’s            
          1982 and 1983 returns pursuant to the closing agreement.  Those             
          adjustments resulted in deficiencies for 1982 and 1983, which               





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