length of the contract — Taxpayer had outstanding variable prepaid forward contracts with two investments banks as the respective counterparties — Counterparties agreed to extend the length of the contracts in exchange for cash consideration from the taxpayer — Taxpayer took the position that there had been n

d Swaps that are executed by such agent on behalf of Counterparty. Moreover, if this letter is being executed by an agent on behalf of one or more Counterparties, the agent should insert before the signature: "as agent for [insert name of account, client, fund, investor and/or other principal] OR [the accoun

e executed by such agent on behalf of Counterparty. Moreover, if this letter is being executed by an agent on behalf of one or EFTA01471490 more Counterparties, the agent should insert before the signature: "as agent for [insert name of account, client, fund, investor and/or other principal OR [the accoun

e executed by such agent on behalf of EFTA01471510 Counterparty. Moreover, if this letter is being executed by an agent on behalf of one or more Counterparties, the agent should insert before the signature: "as agent for [insert name of account, client, fund, investor and/or other principal OR [the accoun