-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 of
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