-31- allocated to THEI and 15 percent, or $217,404, would be allocated to Dondi. These allocations, when added to the previously accumulated capital accounts, result in a total capital of $16,328,755--the amount of the previously identified liquidation proceeds. Petitioner maintains that a liquidation of all of IHCL's assets at the end of 1991 would yield proceeds of $17,887,056. This amount is computed as follows: 12-31-91 Deemed Liquidation Cash $9,098,388 Organization costs 39,388 Note receivable from THEI 2,619,833 Investment in Pacific Gateway 2,660,677 Investment in Pacific Landmark (3,967,304) Liabilities (1,847) Subtotal 10,449,135 1991 Minimum gain chargeback from Pacific Landmark 7,437,891 Distributable liquidation proceeds at book value 12-31-91 17,887,026 This $17,887,026 amount is $1,558,301 more than that for the previous year (1990), consisting of an additional $67,914 in minimum gain chargebacks, plus partnership income for 1991 of $1,490,387. The total liquidation proceeds, as determined by petitioner, would again eliminate THEI's negative capital account. These allocations, when added to the previously accumulated capital accounts, result in a total capital of $17,887,056--the amount ofPage: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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