Thomas Frederick Dadian and Lois Ann Dadian - Page 11

                                       - 11 -                                         
                     Activity                               Date                      
          Petitioners file their 1984                  Apr. 15, 1985                  
            return                                                                    
          Pre-TEFRA test cases begin in                1989                           
            Tax Court                                                                 
          Ms. Sullivan is assigned to                  May 1991                       
            Swanton programs                                                          
          Tentative basis of settlement                Sept. 1991                     
            is reached for TEFRA                                                      
            Swanton programs                                                          
          Respondent files last brief in               Aug. 14, 1992                  
            pre-TEFRA Swanton Tax Court                                               
            litigation                                                                
          Final agreement on terms of                  Sept. 1993                     
            settlement is reached                                                     
          Ms. Sullivan sends closing                   February/March 1996            
            agreements to Redwood                                                     
          Redwood’s TMP and counsel                    End of 1997                    
            inform Ms. Sullivan that                                                  
            the computations for                                                      
            Redwood were based on                                                     
            incorrect investment                                                      
            numbers                                                                   
          Ms. Sullivan sends revised                   First quarter 1998             
            closing agreements to                                                     
            Redwood                                                                   
          South Bay’s TMP signs closing                Mar. 13, 1999                  
            agreement                                                                 
          Respondent countersigns South                July 19, 1999                  
            Bay closing agreement                                                     
          Respondent issues notice of                  Feb. 9, 2000                   
            adjustment to petitioners                                                 








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