ACM Partnership, Southampton-Hamilton Company, Tax Matters Partner - Page 118

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          recognizing this transaction cost, the partnership included it in           
          the carrying cost of the LIBOR Notes.  Although this method of              
          accounting was calculated to result eventually in the allocation            
          of all of the transaction cost to Kannex's partners, as long as             
          recognition of the cost was deferred, the capital accounts of               
          Kannex's partners were overstated, and Kannex's share of                    
          partnership income was understated.  According to the revaluation           
          worksheets, the partners' capital account balances as of the end            
          of FYE 11/30/89, were restated at fair market value as follows:             
               Kannex         MLCS      Southampton         Total                     
          $170,617,686    $603,976    $35,145,281      $206,366,943                   
          (82.68%)       (0.29%)      (17.03%)          (100%)                        
          Had the $1,093,750 discount been recognized and allocated, say,             
          entirely to Southampton at this time, Kannex's pro rata interest            
          in partnership assets and share of partnership income would have            
          been .4402742 percentage points higher and Southampton's .4402742           
          percentage points lower:                                                    
               Kannex         MLCS      Southampton         Total                     
          $170,617,686    $603,976    $34,051,531      $205,273,193                   
          (83.12%)       (0.29%)      (16.59%)          (100%)                        
          This .4402742 percentage point discrepancy corresponds to                   
          Kannex's allocable share of the discount:                                   
               $205,273,193 x .4402742% = $903,765 = $1,093,750 x                     
               82.63%.                                                                








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