Patricia A. Hendricks and John J. Hendricks - Page 8

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          lessee and Colmeno of Colorado, Inc., as lessor.  The lease                 
          commenced in January 1994, and was to run until 2003.  The                  
          arrangements required Mr. Hendricks to make annual payments                 
          totaling $350,550 consisting of payments for the land lease, an             
          equipment lease, a loan of $655,600 from a firm called Menotex, a           
          prior mortgage, and real property taxes.  The farming enterprise            
          failed because Mr. Hendricks was unable to meet the income                  
          projections needed to service the payments.  On February 21,                
          2001, he liquidated the farming enterprise and sold its assets at           
          an auction.  It took Mr. Hendricks until January 2004 to finally            
          pay off all creditors from that undertaking.                                
               On June 18, 1998, we issued an Order to Show Cause why the             
          Boulder Oil and Gas case should not be decided in accordance with           
          several test cases.  On November 23, 1998, we issued an Order and           
          Decision granting respondent’s Motion for Entry of Decision,                
          making adjustments to the partnership items of Boulder Oil and              
          Gas for the 1983 tax year.                                                  
               On October 14, 1999, respondent sent a letter to the                   
          Hendrickses transmitting a Form 4549A-CG, Income Tax Examination            
          Changes, explaining how the adjustments made during the TEFRA               
          proceeding affected their individual income tax return for 1983.            
          Respondent assessed the Hendrickses’ deficiency for 1983 on                 
          February 16, 2000.                                                          

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