Arlene Nussdorf, et al. - Page 3




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               On November 18, 1999, each of the flowthrough entities                 
          purportedly entered into two option trades involving                        
          Euros with AIG International, Inc. (AIG).  One of those option              
          trades was the purported purchase from AIG on November 18, 1999,            
          of an option for a stated volume of Euros, which petitioners                
          refer to as the purchased Euro option.  The second option trade             
          was the sale to AIG on the same date of an option for essentially           
          the same volume of Euros but at a different so-called strike or             
          exercise price, which petitioners refer to as the sold Euro                 
          option.  The two option trades with AIG into which petitioners’             
          respective flowthrough entities purportedly entered on November             
          18, 1999, may be summarized as follows:                                     

                                            Payoff Amount                             
                                               (U.S. $                                
                           Option Premium    Equivalent)     Strike Price             
          Long Position      $26,700,190     $548,240,768       1.0535                
          Short Position     $26,433,172     $548,761,167       1.0545                
          (For convenience, we shall sometimes refer collectively to the              
          purported purchased Euro option and the purported sold Euro                 
          option as the Euro options.)                                                
               On November 30, 1999, petitioners’ respective flowthrough              
          entities purportedly contributed their respective Euro options              
          and $667,500 in cash to Evergreen Trading in exchange for                   
          slightly less than a one-third member or partner interest                   
          therein.                                                                    







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