David Soward - Page 3

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          in Sixty-Three Strategic Inv. Funds v. United States, at Case No.           
          3:05-cv-01123-VRW, in the U.S. District Court for the Northern              
          District of California, San Francisco, on March 17, 2005                    
          (District Court case).  Petitioner, on behalf of Voltaire, filed            
          a petition with respect to the FPAA in the Tax Court on May 13,             
          2005, titled Alverstone Strategic Inv. Fund, L.L.C., Voltaire               
          L.L.C., A Partner Other Than the Tax Matters Partner v.                     
          Commissioner (docket No. 8753-05).                                          
               The Government filed a motion to dismiss for lack of                   
          jurisdiction in the District Court case.  Presidio filed a notice           
          of election to intervene and a motion to dismiss for lack of                
          jurisdiction in the Tax Court case at docket No. 8753-05 on                 
          January 17, 2006.  The District Court case has been stayed until            
          at least January 16, 2007, because of the pendency of a criminal            
          tax case in the District Court for the Southern District of New             
          York involving certain principals of Presidio.  The Tax Court               
          case at docket No. 8753-05 has been held in abeyance pending                
          resolution of the related District Court litigation.                        
               A statutory notice of deficiency with respect to his 1999              
          tax year was sent to petitioner on June 27, 2005.  Respondent               
          determined a deficiency of $1,714,353 for that year.  In the                
          notice of deficiency, respondent made adjustments to petitioner’s           
          income as follows:                                                          







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