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66 66 DB III DB III
Partnership (Pet.) (M&A) DB II (Pet.) (M&A) CAG
% Owned 3% 2% 4% 4% 1% 2%
% Used as 13% 12% 4% 3.75% 1.5% 1.5%
collateral
1 Respondent has conceded that petitioner used as collateral
his entire interest in 66 Farmout (both the interest held in his
name and the interest held in the name of M & A Interest), and 50
percent of his interest in Dime Box No. III held in the name of M
& A Interest. See infra note 6.
Thus, petitioner pledged 100 percent of 66 Farmout held in
petitioner's name, 100 percent of 66 Farmout held in the name of
M & A Interest, 100 percent of Dime Box No. II, 93.75 percent of
Dime Box No. III held in petitioner's name, 50 percent of Dime
Box No. III held in the name of M & A Interest, and 75 percent of
CAG Farmout. In 1987, the holders of the loans foreclosed on the
portions of petitioner's interests in the partnerships that
secured the loans. At the time of foreclosure, the fair market
value of petitioner's foreclosed interests in the Dime Box No.
II, Dime Box No. III, and CAG Farmout partnerships, collectively,
was $60,000.
Basis and Capital Account
Prior to the foreclosures, the only property petitioner
contributed to the partnerships was cash. Similarly, the only
property the partnerships distributed to petitioner was cash.
The following table shows adjustments to petitioner's capital
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Last modified: May 25, 2011