Patricia A. Hendricks and John J. Hendricks - Page 7

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          return.  The only other correspondence sent to the Hendrickses              
          was a Notice of Final Partnership Administrative Adjustments                
          (FPAA) mailed to the Hendrickses on February 6, 1989.                       
               On April 20, 1989, Boulder Oil and Gas filed a petition with           
          the Court in response to the FPAA (Boulder Oil and Gas case).               
               On October 31, 1997, Mr. Hendricks transferred his jointly             
          held interest in the remaining condominiums to petitioner.  For 2           
          years before the transfer of his interest in the remaining                  
          condominiums, Mr. Hendricks had been advised by his attorney and            
          John Angeli (Mr. Angeli), the Hendrickses’ new certified public             
          accountant, to transfer his interest in the condominiums to                 
          petitioner in order to protect the condominiums from any                    
          creditors of Mr. Hendricks in the substantial farming enterprise            
          Mr. Hendricks was engaged in at the time.  Mr. Hendricks’s actual           
          intent in making the transfers was to protect the investment in             
          the condominiums because they constituted the Hendrickses’ only             
          financial resource for their retirement outside of Social                   
          Security.  At the time of the transfer, the Hendrickses                     
          mistakenly believed that they had settled the 1983 tax year and             
          did not owe any tax liabilities associated with 1983 or any other           
               The farming enterprise Mr. Hendricks was engaged in at the             
          time of the transfer to petitioner involved a 10-year lease-                
          purchase of 12,270 acres of Colorado farmland between him as                

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