EFTA Document EFTA01386200

AGP LP 519 Alpha Group Capital Paul Barrett The Partnership intends to take the position that income and losses of the Partnership are not income and losses from a "passive activity" within the meaning of Section 469 of the Code. Accordingly, (i) the deduction by a Limited Partner of his or her share of the losses or deductions of the Partnership will not be restricted under Section 469 of the Code, and (ii) a Limited Partner who is an individual will not be able to deduct losses from other