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Details of Tax Advice

Schedule B

(A separate Schedule B must by submitted for each transaction checked in Section II of Form 13750, where a

written tax opinion for that transaction was obtained, as indicated in Section IV, Item 2 of Form 13750)

Indicate the notice, ruling or other transaction description for the box checked in Section II to which this Schedule B applies

Tax Opinion Matters

1. Did you receive a written tax opinion. If Yes, include a copy with your election

(Note: If you received a written opinion, failure to include a copy will disqualify you

Yes

from consideration for relief under this section)

Yes

2. Did you receive the written tax opinion before filing the affected tax return(s)

3. Did you implement the transaction as described in the opinion. If No, complete item 4

Yes

4. Describe how you implemented the transaction differently from the description in the opinion received

5. Was an independent written appraisal obtained to support the written tax opinion

Yes

(If Yes, include a copy with your election)

Taxpayer – Tax Advisor Relationship Matters

6. Was a tax advisor recommended by a promoter of the transaction

Yes

7. Who recommended the tax advisor

8. Did you have a retainer or other agreement with the tax advisor setting forth

Yes

the terms of engagement. (If Yes, include a copy with your election.)

9. Who paid the advisor's fees

I did

Another individual (Please provide individuals name)

10. How much were the advisor's fees (by year)

11. Were the advisor's fees contingent upon the intended tax benefits

Yes

(If No, please describe the fee arrangement in item 13)

12. To your knowledge, did the advisor issue similar tax opinions regarding the

Don't know

Yes

transaction to other taxpayers

13. Additional information

Paperwork Reduction Act Notice: We ask for the information on this form to carry out the internal revenue laws of the United States. We need it to

insure that taxpayers are complying with these laws and to allow us to figure and collect the right amount of tax.

You are required to give us the information if you are applying for a reward.

You are not required to provide the information requested on a form that is subject to the Paperwork Reduction Act unless the form displays

a valid OMB control number. Books or records relating to a form or its instructions must be retained as long as their contents may become material in

the administration of any internal revenue law. Generally, tax returns and return information are confidential, as required by Code section 6103.

The time needed to complete this form will vary depending on individual circumstances. The estimated average time is 300 minutes. If you have

comments concerning the accuracy of these time estimates or suggestions for making this form simpler, we would be happy to hear from you. You can

email us at *taxforms@irs.gov (please type "Forms Comment" on the subject line) or write to the Internal Revenue Service, Tax Forms Coordinating

Committee, SE:W:CAR:MP:T:T:SP, 1111 Constitution Ave. NW, IR-6406, Washington, DC 20224.

Catalog No. 47521K

13750

Form

(10-2005)

Form 13750 - Election To Participate In Announcement 2005-80 Settlement Initiative - 2005 Page 4

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