Department of the Treasury

Department of the Treasury Internal Revenue Service PO BOX 409105 Ogden UT 84401 FINANCIAL TRUST COMPANY INC % PAUL HOFFMAN 6100 RED HOOK QTRS STE B3 ST THOMAS VI 00802-1348 RECEIVED DEC 21 2010 Financial That Co. XXXXXXXXIOCXXXXMCXXXXX XXXXX)OOCXXXXXXXXXXXXX XX)OOOOOOOOOOOOOCOOCXX XVOCXX)OOOOOOOOOOCXXXX XX1OOOOOOOOOOCXXXXXXXX MOCCOCCXXXXX)OOOOOOOOC EFTA01128322 Department of the Treasury Internal Revenue Service PO BOX 409105 Ogden, UT 84401 FINANCIAL TRUST COMPANY INC % PAUL HOFFMAN 6100 RED HOOK QTRS STE B3 ST THOMAS VI 00802-1348 Dear Dear Mr. Hoffman: Mall Stop: 4520 Date: December 20, 2010 Taxpayer Identification Number: 66-0567418 Tax Year(s): 2007 Person to Contact: Ms. Jasman Contact Identification Number: 0728034 Contact Telephone Number/Fax Number: (801) 620-2456 / (801) 620.2414 Not a toll free number Contact Hours/Days: 7 a.m. • 1 p.m. Mountain Time Monday - Friday Partnership/S Corporation: Prentice Capital Partners OP LP Tax Identification Number: 73-1728934 The partnership in which you have invested, Prentice Capital Partners QP LP, 73-1728934, for tax year(s) 2007, is subject to possible adjustments from a TEFRA examination. Any changes made to the partnership's return as a result of this examination may result in a corresponding adjustment to your return as well. Our records show that there has not been a return filed for the identification number shown on the Schedule K-1. In order to accurately make any necessary adjustments, please check your records and advise us where the amounts shown on the Schedule K-1 are repotted. Older returns are still needed. The normal Statute of Limitations on a taxpayer account is governed by IRC §6501 which states that the statute expires three years from the due date of the return or the date the return was filed, whichever was later. However, the TEFRA provision enacted in 1982 ensures the statute on a flow-through issue is protected at the partnership level (IRC §6229). This means since the statute is held open and protected at the partnership level, the statute of any taxpayer who is an investor in a TEFRA partnership under examination is also held open and protected as long as the flow-through issue is unresolved. If you have additional questions, you may contact the Tax Matters Partner for Prentice Capital Partners QP LP. The Tax Matters Partner has the responsibility to provide this information to investors. Please mail or fax your response within 30 days of the date of this letter. Please include your phone number, convenient hours we may reach you, and a copy of this letter in your reply. On the top of your return, please write in red "COPY DO NOT PROCESS." If you no longer have copies of the requested retum(s), please reply to us so we may continue to process your account as quickly as possible. If we do not receive a copy of your return, we will have to adjust your account using only the information we have available. This will likely result in your receiving an incorrect and potentially higher tax assessment. TTE 4 (Rev. 06-2010) EFTA01128323 In most cases, you will not need to file an amended Federal tax return regarding the examination of the partnership. We will niake the necessary adjustments to your tax account. If you have questions about this matter, please contact the person whose name, telephone number, and contact hours appear above. Unfortunately, long-distance charges will apply if the number is outside your local calling area; however, this person is best qualified to answer any questions you may have about this matter. If you prefer, you may call the Internal Revenue Service phone number listed in your local telephone directory. We apologize for this inconvenience. Sincerely, ifs. 'adman Ms. Jasman Tax Technician Exam Field Support Enclosure(s): Copy of this letter Envelope Copy of K-1 Notice 609 TTE 4 (Rev. 06-2010) EFTA01128324 Department of the Treasury Internal Revenue Service PO BOX 409105 Ogden, UT 84401 FINANCIAL TRUST COMPANY INC % PAUL HOFFMAN 6100 RED HOOK QTRS STE B3 ST THOMAS VI 00802-1348 Dear Dear Mr. Hoffman: Mall Stop: 4520 Date: December 20, 2010 Taxpayer Identification Number: 66.0567418 Tax Year(s): 2007 Person to Contact: Ms. Jasman Contact Identification Number: 0728034 Contact Telephone Number/Fax Number: (801) 620.2456 / (801) 620-2414 Not a toll free number Contact Hours/Days: 7 a.m. • 1 p.m. Mountain Time Monday • Friday Partnership/S Corporation: Prentice Capital Partners OP U' Tax Identification Number: 73-1728934 The partnership in which you have invested, Prentice Capital Partners QP LP, 73-1728934, for tax year(s) 2007, is subject to possible adjustments from a TEFRA examination. Any changes made to the partnership's return as a result of this examination may result in a corresponding adjustment to your return as well. Our records show that there has not been a return filed for the identification number shown on the Schedule K-1. In order to accurately make any necessary adjustments, please check your records and advise us where the amounts shown on the Schedule K-1 are reported. Older returns are still needed. The normal Statute of Limitations on a taxpayer account is governed by IRC §6501 which states that the statute expires three years from the due date of the retum or the date the return was filed, whichever was later. However, the TEFRA provision enacted in 1982 ensures the statute on a flow-through issue is protected at the partnership level (IRC §6229). This means since the statute is held open and protected at the partnership level, the statute of any taxpayer who is an investor in a TEFRA partnership under examination is also held open and protected as long as the flow-through issue is unresolved. If you have additional questions, you may contact the Tax Matters Partner for Prentice Capital Partners QP LP. The Tax Matters Partner has the responsibility to provide this information to investors. Please mail or fax your response within 30 days of the date of this letter. Please include your phone number, convenient hours we may reach you, and a copy of this letter in your reply. On the top of your return, please write in red "COPY DO NOT PROCESS." If you no longer have copies of the requested retum(s), please reply to us so we may continue to process your account as quickly as possible. If we do not receive a copy of your return, we will have to adjust your account using only the information we have available. This will likely result in your receiving an incorrect and potentially higher tax assessment. TTE 4 (Rev. 06-2010) EFTA01128325 In most cases, you will not need to file an amended Federal tax return regarding the examination of the partnership. We will make the necessary adjustments to your tax account. If you have questions about this matter, please contact the person whose name, telephone number, and contact hours appear above. Unfortunately, long-distance charges will apply if the number is outside your local calling area; however, this person is best qualified to answer any questions you may have about this matter. If you prefer, you may call the Internal Revenue Service phone number listed in your local telephone directory. We apologize for this inconvenience. Sincerely, Me. Jam= Ms. Jasman Tax Technician Exam Field Support Enclosure(s): Copy of this letter Envelope Copy of K-1 Notice 609 TTE 4 (Rev. 06-2010) EFTA01128326 In final K.1 ArnitiVed K.I OUR No. 15464:099 Schedule K-1 1- UV I (Form 1065) For calendar year 2007. or lax Department of the TTTTT lay year besinrina Internal Revenue Sento ending Partner's Share of Income, Deductions, Credits, etc. l• Soo back el loan me Hearses lestressises. Part III Partner's Share of Deductions, Credits, Current Year Income, and Other Items 1 Ofeleitiry Dothan IliCanie (loss/ 15 Creills 2 NM rental real ettele Income (Joss) 3 Other nel rental Amami tloss) 16 A Foreign Vertiewora VARIOUS A Part I Information About the Partnership number Pliftlenhps employer stonlikaan 73-1728934 4 Ouronlood payments e 742,822 B Pamorships name. address. csly, slate. and ZIP cede PRENTi CO CAPITAL PARTNERS QP, L.P. 623 Fine AVENUE, 32ND FLOOR NEN YORK, NY 10022 5 rarest tome C (18,556) II Ordinary amends I) 1,169 60 Quellled Oviderds 0 27,531 C IRS Card., when Panner5HP MOO (Hun, OGDEN, UT 7 Royekts D Check it this is a petlicly Boded portneriMp (PTP) 8 NM $117n-loan DOW 96n 0041) fla Net lettlarril apts. sari (loss) 17 Allemalkee rearirraim In (µT) Kenn Part II Information About the Partner It Catedltles (2S%) gen lion).; E l number Sc Unrecaplund Sedan 1250 geln, , .... ,... ''' • N'..'/ F Partners name address. vv. male. end ZIP code Palm( IN1 FINANCIAL TRUST COMPANY, INC. 6100 RED HOOK QUARTER, STE B-3 ST THOMAS, US VIRGIN ISLANDS 00802 i i. r 10 'NM Wien 1231 saln(loss) .'' 1.',. i l Nt.h is Tonicrewq fah* and nondeductible expenses 11 .1 O r , ClherE)COMOOOSO % , /.- (201,662) Fe 0 H I J I( ❑General partner or LID merreer.moneger El tehadittrineroldthoiTh.A.0 '' l 1 `1 557,4(5 Minter \ 1 \ / I F3 Oomeslie partner . . Forelgn potter 1 i '14.. 12., $edlon1796xludin tewiracencen It A Oitivitulkus Mat type *fenny Is Ws earner? Penner, share cd profitless. and CORK eaelnaleg Prat VARIOUS / I ..) CORPORATION .. 13 Go 27,531 lading VARIOUS 20 V* COW Inlennidion SEE SINT Loss VARIOUS VARIOUS Capitol VARIOUS 6.11311 Mt SEE SPOT NOW. Share or liablIdles al year end' Mcnrocourso Quelled nenreoaurse Malkin] Ro:CurSO 14 SelleMOleyinenl earnings (Sass) 'See attached statement for additional Information. : D to IX O U. L Perkier(' ceposi account analysis' Beginning capital account . . . COIN ccontruted &Ono ihe year Current yew Increase (deueeso) . mamas I cOsinbubons . . . Ending cant., account . . . 15,135,796 (2,016,152) 13,119,637 Section 704(b) book . Tax WSJ. Ei GPAP • 00enor (explen) For Paperwork Reduction Act Notice. see Instructions for Fenn 1066. EFTA01128327 SC.4143thita K.1 (Form 1065) 2007 Page 2 This list identifies the codes used on Schedule K-1 for all partners and provides summarized reporting Information for partners who file Form 1040. For detailed reporting and filing information, see the separate Partners Instructions for Schedule I4.1 and the instructions for your income tax return. 1. ordinary business Income (less). You must first determine whether the Income (loss) is passive or noripassree Then erect an yotr return as Idlows Paint loss Panne inform Nonpassive Foss Norpostiee income 2. Net reMal real estate Income (loss) 3. Other net rental Income Bassi Nel Income trot loss 4. GuaraMeed payments 6. Interest Income GE Ordinary dividends GO. Qualified dividends 7. Royalties a. Not ShOitterm capital gain floss) 9a. Net long4enn capital gain (loss) 90. Collectibles (it%) gain (loss) 9c. Uniciaptured section 1260 gain 10. Net seCtIon 1231 gain (loss) It Other Income floss) Coda A Cmar pOrtfolo income (loss) B Ineaureary oonveisre C Sec 1256 contracts & Mractilles O Miring coporabon costs recapture E Canoolanon ordeal F Other ncome (l03S) 12. Section 179 deduction 13. Other deductions A Cash cortibutiOns (50%) B Cash corinbulans (30%) C Non:ash ceitntutiom (50%) • Noncash contnbthiOnS (30%) E Caoralgain property to a 50% organizabon (30%) F Geoid gain property 120%) • Inmstment Moron expense H Oeductions—royally income I Section 59(0(2) experaures J DoduCtions—porttoto (7% e000 K DeduclOns—portlofio Comp) L Amain:I paid for medial insurance M Educational assistance benefits N Dependent care benefits O Reproductive period expenses P Commerce] roittalzalion deduction Iran rental real estate activne I O Pensions and IRAs R Rehowstalon capons* deduction S Domestic production acliAtes irformihon T Ovaified production acimraes noon. U Ernabrets Form W.2 wages  Other deductions RePOrl on See the PartherS Instructions Sc eilde E. line 28. Column (g) Sche&se E. line 28. adumn (h) Sc1140,0 E. In, 28. °durum 0) See me Partners Instructions Schedule E. In, 28. colcenn (g) See Me Partners thieve-bons SChedile E. hie 28. coluim 0) Form 1040. line Si Form 1040, line Si Form 1040 toe fib Schedule E. Ine 4 Schedule 0. line 5. cdornn (f) Sandal, 0, line 12. column (I) 28% Rate Gain Vikirkshiset. fire 4 (SChedule D vitro:tons) Set the Partners Instmcbons Soo the Partners Instructions See the Partner's Instructions Soo the Partners Instructions Form 6781. line 1 See Pub 515 Form 1040, hoe 210t Feiem 982 See tve Partners InStruChans See the Pants InSIntlians Sea the Panne s Instrucbons form 4952, lino 1 •h Sch&kile E. Ire 10 See the Partners Instructions Schedule A. line 23 Schedule A, line 28 ) Schedule A 'no 1 Cr Form 1040 lino 29 See the Fanners tlittliTSOns Form 2441. lino 14 Soo the Partners Instructions See Form 8582 insoudicns See tie Partners Instructions See the Partners Instructions See Fenn 8903 instructions Form 8933, line 7 Form 8903. line IS See the Partners Instructions 14, Selhemploythent earnings (loss) Not*. 7f 10u nave a section 179 otootradn Or any partner-level dedocnons. see tno Partners hisltuatians Wont completes) SCAeclute SE. A Nel earnings noss) from sell .ernployrnent B Gross tamer* Or saran° mcame C Gross nonfarm Income 16. Credits A Lowincome hOusing creel (section 421)xs)) B Low-VICOMO nothing Creel (0APP) C Quashed iehotilealies experidoures See the Parthees Institotons (rental real estate) ▪ Other tones, real estate credits E Other tens emits F Unclittntheed CtioLII gains creel Form 1040, lino 70. Check box a O Gait for alcohol used as tool H Work Opportunity Neel I Wattare40.werk wedil J Disabled IrCtlaS CrOcH SChedise SE. Section A or B See MO Partners !Otto/client Soo me Partners Instructions Soo Po Partners Instructions Code Roporl On K En1pOwlyinp11 zone and rennet' COMMuney OMMOyinent creel L Credit kie incioasng research adivaes M Nen makers credit N Grail for erroloyer social security rd Medics* taxes 0 BackupMirth:Wog P Other Neils 16. Foreign transactions A Name of country or U S. possession B Gross income Iron al sources Form 1118. Pan I C Gross income sourced at partner 11 level Foreign gross income sourced al PaleorognP Jowl O Passive category E orel category F Cesar &m ry I Fonn 1116, Part I Deductions altocatod and appOrloned of partner level • Mores, expense Form 1118 Pan I H Other Foos 1116, Pan I Declections alticaled and appadoned at partnersMplevel to foreign source income I Passive category J Gime& coiner), Form 1116. Pail I K Other aner information L Total foreign laves pad M Total Vogl lanes accrued Reduction in taxes available for Credit O Foreign Vain) gross receipts P Extralornalal income eadistiOn 0 Other forage, transacsons 17. Alternative minimum tax (Ala) Rems A Post.106 dirmaton **Montt B Mush:again or loss • C Depletion (oiler than or: 8 Oat) 0 Of gos, 6 geothermal—gross income E 01. gas. S. 9*011C1111X--0410a11 F Other AMT items 18. Tax-exempt Income and nondeductible *ripen A lax-exempt imotest income B Other tex-exernpl income C NondeiduTt tile expenses 19. Disldbutions A Cash and markerado secinties B Other property 20. Other Information A Investment income B Investment expenses C RAH la °odd inlorrnalien to assailed rehabilitation expendeses (other than rental real estate) E Basis of °nets, peppily F Recapture of Impircoma Meitanii Creel (sotto, 421.(5)) O Recapture of lowincomo Must% veil (other) N ReCarJal c4 nvestrneN coda I Recapture Of other crafts Look-back Inlerest—completed loneltnn conned. K LOOlobOCk Merest—income forecast method I Cuposicins of Fcripeny rim socbcn 179dodo:Oen, M Recapture of moon 179 deduction N Interest expense for corpora* partners O Somon 4530)(3) informatnn P Section 4534(c) irformaton O &Mien 1280(0) inIccmation R thieves' steads to prOJVCken eipanditures S CCF nonoirified hitharaNals T irrom-alco needed to ' ,pure OCIZie.0.1—Ct3INJ gas U Atit0411231co of reforestaten cosh  Urn:WM busmen. remote 'eerie W Goner irdommton Form 8844, Ices 3 / Sect the Partners Intel/0qm Form 1040. M004 See the Partners Instriol ohs Form 1116. Pan II Fans 1116. Part II Fans 1118 kw 12 Form 8873 bconto373 See the Partner's Instructions } See In Partners Instructions and the inS1/1.00XIS for Fonn(1251 a Form 1040, Me Ott Soo Me Pinner% Intim:tons See tie Palsies Instructions Soo the Parinces 'narwhals See the Partners Instructions Form 4957 line 4a Form 4952, line 6 Ferro 4138 See the Pasant, Insinxtions See tie Pannell Instructions Form 8811. line 8 Form 9611. Mel) See Ferns 4255 See ma Pilaw% insIngtais Soo Form 6697 See Form 8866 See me Painters thsthicnons EFTA01128328 PRENTICE CAPITAL PARTNERS OP.. Partner #6 73.1728934 SCHEDULE K-1 SUPPORTING SCHEDULES FINANCIAL TRUST COMPANY. INC. PART II, ITEM L, CURRENT YEAR INCREASE (DECREASE) INCOME (LOSS) FROM SCH. K-1, BOXES 1 - 11 LESS: DEDUCTIONS FROM SCH. K-1, BOX 12, 13, 16L & 16M TOTAL INCOME (LOSS) PER SCHEDULE K-1 UNREALIZED GAIN/(LOSS) AND OTHER TEMPORARY DIFFERENCES TRANSFER IN TRANSFER OUT REDEMPTIONS PAYABLE 355,803 27,531 328,272 (2,344,431) CURRENT YEAR INCREASE (DECREASE) (2,016,159) BOX 11, CODE C - SECTION 1256 CONTRACTS & STRADDLES NET SECTION 1256 GAIN (LOSS) FROM TRADING ACTIVITIES (1040 FILERS ENTER ON FORM 6781, LINE 1, GAIN COL. C (LOSS) COL. B) TOTAL SECTION 1256 CONTRACTS & STRADDLES BOX 11, CODE F - OTHER INCOME (LOSS) (201,662) (201.662) NET ORDINARY INCOME FROM TRADE OR BUSINESS ACTIVITY BEFORE DIVIDEND INCOME 93,632 (SEE SEPARATE FOOTNOTE BELOW FOR DETAILS) (1040 FILERS ENTER ON SCH. E, PART II. INCOME COL. J, (LOSS) COL. H) TOTAL ORDINARY TRADE OR BUSINESS DIVIDENDS c" 279,970 (1040 FILERS ENTER ON FORM 1040, LINE 9A) (SEE SUPPLEMENTAL FOOTNOTE) TRADE OR BUSINESS CAPITAL GAINS (LOSSES): ' NET SHORT-TERM CAPITAL GAIN (LOSS) ( 715.990 (1040 FILERS ENTER ON SCH. D, LINE5.COL. F) \\\ NET LONG-TERM CAPITAL GAIN (LOSS) \ (532,127) (1040 FILERS ENTER ON SCH. D, LINE 12, COL, F) TOTAL OTHER INCOME (LOSS) \ • ` 557,465 DETAIL OF NET ORDINARY INCOME (LOSS) FROM TRADE OR BUSINESS ACTIVITY BEFORE DIVIDEND INCOME INCLUDED ON SCH. K-1, BOX 11, CODE F: INTEREST INCOME 301,610 IRC SEC. 988 INCOME (LOSS) (FOREIGN CURRENCIES) (757) TRADE OR BUSINESS INTEREST EXPENSE OTHER TRADE OR BUSINESS EXPENSES (387,019) OTHER ORDINARY INCOME 179.798 TOTAL ORDINARY INCOME (LOSS) 93.632 SUPPLEMENTAL FOOTNOTE - DIVIDEND INCOME INCLUDED ON SCH. K-1, BOX 11, CODE F: QUALIFIED DIVIDENDS 5,350 • (1040 FILERS ENTER ON FORM 1040, LINE 9B) BOX 13, CODE G - INVESTMENT INTEREST EXPENSE INVESTMENT INTEREST EXPENSE RELATED TO TRADING ACTIVITIES 27,531 TOTAL INVESTMENT INTEREST EXPENSE 27,531 EFTA01128329 PRENTICE ,CAPITAL PARTNERS OP. L.P. Partner #6 73-1728934 SCHEDULE K-1 SUPPLEMENTAL DETAIL FINANCIAL TRUST COMPANY. INC. PARTNER FOOTNOTES: PLEASE NOTE THAT OTHER THAN THE FOOTNOTE MENTIONED BELOW, NONE OF THE DISTRIBUTIVE SHARE ITEMS REPORTED ON SCHEDULE K-1 ARE CONSIDERED AS DERIVED FROM A PASSIVE ACTIVITY UNDER TREASURY REGULATION SECTION 1 469-1T(E)(6) THE FUND DISPOSED OF A PASSIVE ACTIVITY IN 2007. PLEASE NOTE THAT THE AMOUNT REFLECTED ON LINE 1 OF YOUR PRIOR YEAR SCHEDULE K-1S WERE FROM THIS PASSIVE INVESTMENT. THE PASSIVE CAPITAL LOSSES ON THE DISPOSITION OF THIS INVESTMENT ARE INCLUDED IN LINES 11F ARE AS FOLLOWS: SHORT-TERM LONG-TERM PLEASE CONSULT YOUR TAX ADVISOR (142,055) (554,503) THE K-1 HAS BEEN PREPARED ON THE BASIS OF A PARTNER WHO DOES NOT MATERIALLY PARTICIPATE IN THE OPERATIONS OF THE PARTNERSHIP. THEREFORE, INTEREST EXPENSE HAS BEEN INCLUDED IN BOX 13, CODE GAS INVESTMENT INTEREST EXPENSE AND IS NOT INCLUDED IN BOX 11, CODE F. 1040 FILERS SHOULD ENTER THIS AMOUNT ON FORM 4952, LINE 1. ANY DEDUCTIBLE INTEREST EXPENSE SHOULD THEN BE ENTERED ON SCHEDULE E, PART II, COLUMN (H). INVESTMENT INCOME/EXPENSE ITEMS IN BOX 11, CODE C AND BOX 11, CODE F HAVE NOT BEEN INCLUDED IN BOX 20, CODE A AND BOX 20, CODE B. THESE AMOUNTS SHOULD BE CONSIDERED WHEN PREPARING FORM 4952. PLEASE CONSULT YOUR TAX ADVISOR. DOMESTIC PRODUCTION ACTIVITIES INFORMATION, BOX 13. CODE Si IN ADDITION TO THE INFORMATION PROVIDED ON SCHEDULE K-1. THE PARTNERSHIP PROVIDES THE FOLLOWING INFORMATION RELATING TO BOX 13, CODE S: ALL OF THE PARTNERSHIP'S ITEMS RELATE TO NON-DOMESTIC PRODUCTION ACTIVITIES. IF YOU OTHERWISE HAVE SECTION 199 ACTIVITIES, PLEASE NOTE THAT THE INFORMATION NECESSARY FOR PURPOSES OF COMPUTING THE GROSS INCOME/GROSS RECEIPTS IS REPORTED IN BOX'11. CODE F. NET OF LOSSES FROM CAPITAL ASSETS. ADDITIONAL INFORMATION, IF NEEDED. IS AVAILABLE UPON REQUEST. FOREIGN GROSS INCOME SOURCED AT PARTNERSHIP LEVEL, BOX 16. CODE D: FOREIGN QUALIFIED DIVIDENDS ARE INCLUDED IN BOX 16, CODE D. PLEASE CONSULT YOUR TAX ADVISOR REGARDING WHETHER ADJUSTMENTS SHOULD BE MADE TO THIS AMOUNT OR ANY APPEARING IN BOX 16 FOR PURPOSES OF CALCULATING OTHER AMOUNTS YOUR FOREIGN TM CREDITS ON FORM 1116. YOUR ALLOCABLE SHARE OF FOREIGN QUALIFIED DIVIDENDS ARE: 245 BOX 20. CODE P: INFORMATION REGARDING UNRELATED BUSINESS TAXABLE INCOME: -- 00.00% OF OF ALL OTHER ITEMS OF INCOME/LOSS AND DEDUCTIONS OTHER THAN CAPITAL GAINS/LOSSES AND SECTION 1256 GAINS/LOSSES IS UNRELATED BUSINESS TAXABLE INCOME. - 00.00% OF CAPITAL GAINS/LOSSES AND SECTION 1256 GAINS/LOSSES IS UNRELATED BUSINESS TAXABLE INCOME. CORPORATE PARTNERS MAY TAKE THE FOLLOWING DIVIDENDS REPORTED ON SCHEDULE K-1 AS QUALIFYING FOR THE DIVIDENDS RECEIVED DEDUCTION UNDER IRC SECTION 243: 5,104 EFTA01128330