Arlene Nussdorf, et al. - Page 5




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               On January 18, 2000, the remaining balance of the second               
          option was unwound resulting in $79,208,185 received by Evergreen           
          Trading with respect to which Evergreen Trading reported in its             
          2000 partnership tax return a gain of $38,378,419.  A portion of            
          such gain totaling $11,247,796 was allocated to petitioners’                
          respective flowthrough entities.                                            
               During the latter part of March 2000, petitioners’ respec-             
          tive flowthrough entities withdrew from Evergreen Trading and               
          paid a 5-percent withdrawal fee of $159,302.  When such entities            
          withdrew from Evergreen Trading, each received a liquidating                
          distribution of 192,602 Euros with a fair market value of                   
          $185,438.  No other cash or property was distributed to petition-           
          ers’ respective flowthrough entities (or to petitioners in these            
          cases).                                                                     
               On December 17, 2002, respondent issued a notice of begin-             
          ning of administrative proceeding with respect to Evergreen                 
          Trading for the taxable year 1999, and on March 19, 2003, respon-           
          dent issued such a notice with respect to Evergreen Trading for             
          the taxable year 2000.  On September 26, 2005, respondent issued            
          a notice of final partnership administrative adjustment (FPAA)              
          with respect to Evergreen Trading for the taxable years 1999 and            
          2000.                                                                       
               In the FPAA that respondent issued with respect to Evergreen           
          Trading for the taxable years 1999 and 2000, respondent made the            







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