Department of the Treasury — Internal Revenue Service

Form 13751            Waiver of Right to Consistent Agreement of Partnership Items
                                                                                             OMB No. 1545-1969
(October 2005)        and Partnership-Level Determinations as to Penalties,
                                  Additions to Tax, and Additional Amounts
Taxpayer                                             Partnership
1. Name and address (Street, City, State, ZIP code)  3. Name and address (Street, City, State, ZIP code)

2. Taxpayer Identification Number (EIN or SSN)       4. Taxpayer Identification Number (EIN or SSN)

5. Tax year(s) ended

                      The undersigned taxpayer(s), in

                      accordance with Internal Revenue Code

                      section 6224(b), waive(s) the right to

                      request settlement terms with respect to

                      partnership items (and partnership-level

                      determinations of penalties, additions to

                      tax and additional amounts that relate to

                      partnership items) for the above

                      partnership taxable year(s) consistent with

                      settlement agreements entered into with

                      any other partner with respect to the

                      above taxable year(s).

Signature of Taxpayer                                                                   Date (mmddyyyy)

Signature of Taxpayer                                                                   Date (mmddyyyy)

Catalog No. 47541C                                  www.irs.gov                              Form 13751 (10-2005)