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Observation: If the IRA had invested in a publicly traded partnership instead of a nonpublicly traded partnership the results would have been the same. filed a registration statement on Form S-1 with the Securities and Exchange Commission to become a publicly traded partnership through a proposed underwritten initial public offering. It is uncertain whether or not the Offer, if consummated, might cause Patriot to be deemed a "publicly traded partnership" since the Offer by itself and/or in combination with other transfers of Patriot's units, could result in a transfer of more than two percent of the interests in Patriot during the year, which might prevent it from relying on an Internal Revenue Service "safe harbor" protecting against publicly traded partnership treatment. |
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