"The principal design of this scheme is to generate significant capital losses for U.S. taxpayers which can then be used to offset capital gains which would otherwise be subject to tax."

-Undated internal UBS memo regarding FLIP, Bates UBSOOOO06

"KPMG approached us as to whether we could affect the security trades necessary to achieve the desired tax results. *** The tax opportunity created is extremely complex, and is really based more on the structuring of the entities involved in the securities transactions rather than the security transactions themselves."

-Internal Quadra memo regarding FLIP (8/12/96), Bates UBSOOOO02

"Target Customers: Capital Gain of $20 Million or more. Potential Benefits: Individual Capital Gain Elimination."

-Enhanced Investment Strategy Release from First Union (now Wachovia) regarding FLIP (2/2/99), Bates SEN-009397

"7% [is the] fee (equity) paid by investors for tax sheltering."

-Undated notes of HVB Employee regarding BLIPS, Bates HVBOO0204

"It is imperative that the transaction be wound up...due to the fact that the [High Net Worth] individual will not receive his/her capital loss (or tax benefit) until the transaction is wound up."

-Undated Internal Deutsche Bank memo regarding BLIPS, Bates DB BLIPS 01961