Gary D. and Johnean F. Hansen - Page 18

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                    Whether a person meets the material participation                 
               requirement of section 469 is a factual determination.  The            
               Reg. 1.469-5T(f)(2)(ii) defines investors’ activities that             
               are not considered in meeting the hourly requirement.                  
               Simply signing a statement or making an election are not a             
               means in meeting the requirement.  Although Section 469 may            
               not have existed at the time of your initial investment, it            
               is law that investors have to address in claiming investment           
               losses today.  Contrary to Mr. Hoyt’s statement, time spent            
               reading and thinking about this issue should not be                    
               considered as material participation hours for 1992.                   
                    If this letter is somewhat confusing or you are                   
               questioning the accuracy of this letter, I recommend you               
               consider having an independent accountant or attorney review           
               this matter with you.                                                  
          Petitioners also received several notices informing them that               
          respondent was beginning an examination of various partnerships             
          in which petitioners had been involved.  Petitioners received               
          such notices dated June 19, 1989, June 26, 1989, August 13, 1990,           
          January 28, 1991, February 19, 1991, May 13, 1991, February 3,              
          1992, and February 18, 1992.  Finally, petitioners had been                 
          notified by respondent by letter dated December 9, 1988, that               
          their 1987 individual income tax return had been selected for               
          examination prior to issuance of the requested refund; the refund           
          was subsequently issued on February 20, 1989.                               
               In June 1992, petitioners completed their joint Federal                
          income tax return for their taxable year 1991.  They reported the           
          following items of income and loss on this return:                          











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