ACM Partnership, Southampton-Hamilton Company, Tax Matters Partner - Page 72

                                       - 30 -                                         
          and Southampton was therefore necessary for most partnership                
          decisions.  As its representative, Southampton appointed                    
          Pohlschroeder.  Kannex appointed de Beer, and MLCS appointed                
          Taylor.                                                                     
               The Partnership Agreement provided that, in general, income,           
          gain, expense, and loss, as reported by the partnership for                 
          Federal income tax purposes, would be allocated among the                   
          partners in proportion to their respective capital accounts.  As            
          subsequent events would demonstrate, this general sharing                   
          provision did not fully reflect the partners' original                      
          understanding of the manner in which they would share the                   
          economic costs of partnership transactions.                                 
               Upon the occurrence of specified "Revaluation Events", the             
          partnership would revalue its assets on its books, and any                  
          unrealized income, gain, expense, or loss inherent in its assets            
          would be allocated among the partners as if realized in a sale of           
          the assets at their fair market value.  These Revaluation Events            
          included:  (i) a change in a partner's proportionate interest in            
          partnership capital; (ii) a sale or exchange by the partnership             
          of any Colgate debt instrument; (iii) an adjustment to the Yield            
          Component (as defined below) with respect to Colgate debt; (iv) a           
          contribution or distribution of partnership assets;                         
          (v) liquidation of the partnership; (vi) the last business day of           
          each fiscal year; and (vii) after November 30, 1989, the properly           
          executed request of any partner.                                            




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