Ann E. Bartak - Page 10

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               not give effect to the allocation of profits and losses                
               contained in the Partnership Agreement, * * *, (e) the                 
               risk that an audit of the Partnership’s income tax                     
               return may result in an audit of a Limited Partners’                   
               own individual tax return * * *.                                       
                              *   *   *   *   *   *   *                               
               The income tax returns of the Partnership may be                       
               audited, and in turn, such audit may result in the                     
               audit of the returns of each Partner.  In addition, the                
               Commissioner of Internal Revenue has announced that the                
               Service is engaged in a program of intensified audits                  
               of partnerships.  Various deductions claimed by the                    
               Partnership on its returns of income could be                          
               disallowed in whole or in part on audit, which would                   
               result in an increase in the taxable income of the                     
               Partnership, and in turn, each Partner.                                
               If a tax deficiency is determined, the taxpayer is                     
               liable for interest (compounded on a daily basis) on                   
               such deficiency from the due date of the return.                       
                              *   *   *   *   *   *   *                               
               BASED ON THE INVESTMENT OBJECTIVES OF THE PARTNERSHIP,                 
               THE GENERAL PARTNERS BELIEVE THAT THERE ARE SUBSTANTIAL                
               GROUNDS FOR ARGUING THAT THE PARTNERSHIP IS NOT A “TAX                 
               SHELTER.”  HOWEVER, NO ASSURANCE CAN BE GIVEN THAT THE                 
               IRS WILL NOT ATTEMPT TO CLASSIFY THE PARTNERSHIP AS A                  
               TAX SHELTER NOR WHETHER SUCH ATTEMPT WOULD BE                          
               SUCCESSFUL.                                                            
                              *   *   *   *   *   *   *                               
               THE FOREGOING ANALYSIS CANNOT BE, AND IS NOT INTENDED                  
               AS, A SUBSTITUTE FOR CAREFUL TAX PLANNING,                             
               ACCORDINGLY, PARTNERS ARE URGED TO CONSULT THEIR TAX                   
               ADVISORS WITH RESPECT TO THEIR TAX SITUATION AND THE                   
               EFFECTS OF OWNING PARTNERSHIP UNITS.                                   
          Tax Returns                                                                 
               Petitioner and Mr. Bartak filed joint Federal income tax               
          returns for 1980, 1981, 1982, 1983, 1984, 1985, and 1986.  For              






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