Standard Instructions for Filing Forms under the Securities Act of 1933, Securities Exchange Act of 1934, and Energy Policy and Conservation Act of 1975
Regulation S-K
Item 915 -- Federal Income Tax Consequences
Provide a brief, clear and understandable summary of the material
Federal income tax consequences of the roll-up transaction and an investment in the
successor. Where a tax opinion has been provided, briefly summarize the substance
of such opinion, including identification of the material consequences upon which
counsel has not been asked, or is unable, to opine. If any of the material Federal
income tax consequences are not expected to be the same for investors in all partnerships,
the differences shall be described.
State whether or not the opinion of counsel is included as an
appendix to the prospectus. If filed as an exhibit to the registration statement
and not included as an appendix to the prospectus, include a statement to the effect
that, upon receipt of a written request by an investor or his representative who
has been so designated in writing, a copy of the opinion of counsel will be transmitted
promptly, without charge, by the general partner or sponsor. The statement should
include the name and address of the person to whom investors should make their request.
Notice to Users: The Deskbook is made available
with the understanding that the University of Cincinnati College
of Law is not engaged in rendering legal, accounting or other professional
services. If legal advice or other expert assistance is required,
the services of a competent professional person should be sought. See Terms and Conditions of Use.
