Leatherstocking 1983 Partnership, Sam I. Brown, A Partner Other Than The Tax Matters Partner - Page 6

                                         -6-                                          
          June 16, 1991        June 21, 1991     Dec. 31, 1993                        
          Dec. 15, 1993        Dec. 28, 1993     Dec. 31, 1995                        
          May 8, 1995          June 12, 1995     Dec. 31, 1996                        
          Sept. 23, 1996       Oct. 2,  1996     Dec. 31, 1997                        
          The relevant details of the consents for 1984 were as follows:              
          Date signed by       Date signed      Extended date                         
          Steele or Kornblatt    by respondent     for assessment                     
          Feb. 4, 1988         Mar. 1, 1988      Dec. 31, 1988                        
          Sept. 6, 1988        Sept. 13, 1988    Dec. 31, 1989                        
          Aug. 24, 1989        Sept. 8, 1989     Dec. 31, 1990                        
          May 31, 1990         June 8, 1990      Dec. 31, 1991                        
          June 16, 1991        June 21, 1991     Dec. 31, 1993                        
          Dec. 15, 1993        Dec. 28, 1993     Dec. 31, 1995                        
          May 8, 1995          June 12, 1995     Dec. 31, 1996                        
          Sept. 23, 1996       Oct. 2,  1996     Dec. 31, 1997                        
          4.  Steele’s Criminal Activities                                            
               In or about August 1986, Steele and three of his                       
          coconspirators (we refer collectively to Steele and one or more             
          of the conspirators as coconspirators) traveled to Hawaii to meet           
          with Ferdinand Marcos (Marcos), who was then in exile there.  The           
          coconspirators offered to help Marcos return to power in the                
          Philippines.  The coconspirators first offered to return Marcos             
          to power peacefully in return for at least $180,000.  In                    
          September 1986, Marcos transferred $180,000 to the coconspirators           
          by wiring that amount from a foreign account to an account of one           
          of Steele’s corporate entities, Commonwealth Group, Ltd.  In                
          October 1986, Marcos wired another $1 million to the Commonwealth           
          account.                                                                    
               When the peaceful efforts failed, the coconspirators offered           
          to return Marcos to power forcefully by way of a coup.  The                 





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