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Charlie Im a partner at Michael best and Friedrich Im sure of our tax group Ill be speaking first today and and relatively briefly on a tax issue thats come up and then gone away and maybe still here well talk about that and my partner Brent Stewart will speak for really the bulk of the presentation on certain aspects of commercial aspects of non-recourse loans february of this year the IRS office of chief counsel which is the head lawyers at the IRS issued a position paper with respect to contingent get partner guarantees of entity level non-recourse death and people went nuts it was considered a radical change from what everybody thought the wisdom was and the bottom line is that if the position was sustained it would result in partners many many tens of thousands who have been claiming losses in the tens of billions of dollars of partnership flow-through losses those losses being disallowed and typically this comes up with respect to real estate ventures that are operated in pa