Leatherstocking 1983 Partnership, Sam I. Brown, A Partner Other Than The Tax Matters Partner - Page 4

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          2.  Leatherstocking                                                         
               Leatherstocking is a New York limited partnership that was             
          inactive when its petition was filed with the Court.  When it was           
          active, Leatherstocking’s business offices were located in New              
          York, New York.  Leatherstocking’s organizer and only general               
          partner is Steele.  Leatherstocking had 34 limited partners                 
          during each subject year.                                                   
               Leatherstocking’s operation involved a cattle breeding and             
          embryo transfer venture conducted at the Leatherstocking Farm in            
          Easton, New York.  Through the venture, Leatherstocking produced            
          embryos fertilized from Black Angus cows and the sperm of a Black           
          Angus bull named “High Voltage”.  The venture was conducted                 
          primarily as a tax shelter.                                                 
               Leatherstocking was one of many entities formed by Steele in           
          1983 through 1986 to syndicate interests in High Voltage or to              
          own or market cattle or their embryos.  Those entities included             
          eight limited partnerships, the sole general partner of whom was            
          either Steele or his wholly owned corporation.  One of the other            
          partnerships was Leatherstocking High Voltage Limited Partnership           
          (High Voltage Limited Partnership), through which interests in              
          High Voltage were syndicated in 1985.  Another entity was Roblis            
          Enterprises, Ltd. (Roblis), an S corporation wholly owned in form           
          by Steele’s wife.  Roblis owned and operated the Leatherstocking            
          Farm.                                                                       






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