[Code of Federal Regulations]
[Title 17, Volume 2]
[Revised as of April 1, 2001]
From the U.S. Government Printing Office via GPO Access
[CITE: 17CFR229.915]

[Page 440]
 
              TITLE 17--COMMODITY AND SECURITIES EXCHANGES
 
             CHAPTER II--SECURITIES AND EXCHANGE COMMISSION
 
 PART 229--STANDARD INSTRUCTIONS FOR FILING FORMS UNDER SECURITIES ACT OF 1933, SECURITIES EXCHANGE ACT OF 1934 AND ENERGY POLICY AND CONSERVATION ACT OF 1975--REGULATION S-K--Table of Contents
 
                  Subpart 229.900--Roll-Up Transactions
 
Sec. 229.915  (Item 915) Federal income tax consequences.

    (a) Provide a brief, clear and understandable summary of the 
material Federal income tax consequences of the roll-up transaction and 
an investment in the successor. Where a tax opinion has been provided, 
briefly summarize the substance of such opinion, including 
identification of the material consequences upon which counsel has not 
been asked, or is unable, to opine. If any of the material Federal 
income tax consequences are not expected to be the same for investors in 
all partnerships, the differences shall be described.
    (b) State whether or not the opinion of counsel is included as an 
appendix to the prospectus. If filed as an exhibit to the registration 
statement and not included as an appendix to the prospectus, include a 
statement to the effect that, upon receipt of a written request by an 
investor or his representative who has been so designated in writing, a 
copy of the opinion of counsel will be transmitted promptly, without 
charge, by the general partner or sponsor. The statement should include 
the name and address of the person to whom investors should make their 
request.