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               Included as part of the 1998 partnership return for Kildare             
          Timmy’s short and final taxable year was Schedule K-1, Partner’s             
          Share of Income, Credits, Deductions, Etc. (Schedule K-1),                   
          relating to Mr. Ramsburg.  A statement (explanatory statement                
          relating to Mr. Ramsburg’s Schedule K-1) entitled “Schedule K-1,             
          Column C Reconciliation” purported to explain how the amount                 
          shown for 1998 (i.e., a loss of $4,592)10 in Item J, Column (c)              
          of such Schedule K-1 (i.e., Partner’s share of lines 3, 4, and 7,            
          Form 1065, Schedule M-2) was calculated.  The explanatory state-             
          ment relating to Mr. Ramsburg’s 1998 Schedule K-1 showed the                 
          following:                                                                   
                            Description           Amount                               
                      Ordinary Income (Loss)    ($4,592)                               
                       Loss on Disposition1     (69,772)                               
                      Total to Schedule K-1,    (74,364)                               
                         Item J, Column C                                              
               1The explanatory statement relating to Mr. Ramsburg’s Sched-            
          ule K-1 did not provide any details about “Loss on Disposition”.             
               Included as part of the 1998 partnership return was Schedule            
          K-1 relating to Mr. Stottlemeyer.  A statement (explanatory                  
          statement relating to Mr. Stottlemeyer’s Schedule K-1) entitled              
          “Schedule K-1, Column C Reconciliation” purported to explain how             
          the amount shown for 1998 (i.e., $0) in Item J, Column (c) of                
          such Schedule K-1 (i.e., Partner’s share of lines 3, 4, and 7,               
               10The loss of $4,592 is the amount shown in the chart above             
          as Mr. Ramsburg’s distributive share of ordinary loss from trade             
          or business activities.                                                      
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