Investment Research Associates - Page 335




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          that most of the partnership interests held by his grantor trusts            
          had negative capital accounts, and an outright sale would have               
          realized significant gains (assumption of liabilities in excess              
          of the partners' bases).  Specifically, the aggregate negative               
          capital accounts for the interests held by the grantor trusts as             
          of May 15, 1983, was $476,888.60, as follows:                                
          Entity         Partnership Interest        Cap. Acct.                        
          BWK Rev Trust      Bajomonte Associates     ($180,270.00)                    
          BWK Rev Trust       Diversified River Bend                                   
                              Partners                    (37,622.05)                  
          BWK Rev Trust       Diversified Stephenson's                                 
          Lake Partners               (30,364.70)                                      
          Everglades Trusts  Wayside Partners             (4,806.00)                   
          Everglades Trusts  Shady Crest Investors       (36,425.79)                   
          Everglades Trusts  Diversified Raintree                                      
          Partners                    (15,942.00)                                      
          Everglades Trusts  Edgewater Partners          (24,798.38)                   
          Everglades Trusts  Kentucky Holdings            (4,703.19)                   
          Everglades Trusts  Walnut Creek Group           (2,095.05)                   
          Everglades Trusts  Candlelite Apartments       (77,401.56)                   
          Everglades Trusts  Village Square Lexington    (15,032.32)                   
          Everglades Trusts  Wortham Office Mall         (12,751.50)                   
          Everglades Trusts  Kon-Tiki Apartments         (25,606.66)                   
          Everglades Trusts  Diversified Hillsborough                                  
          Partners                      3,979.00                                       
          Everglades Trusts  Manderville Partners         10,353.65                    
          Everglades Trusts  Palo Alto Partners            1,219.11                    
          Everglades Trusts  J.S. Investors                9,305.00                    
          Everglades Trusts  Cove Realty                  14,098.00                    
          Everglades Trusts  Midwest Realty               13,834.56                    
          Everglades Trusts  Washtenew Management          2,766.09                    
          Everglades Trusts  Tradewinds Shopping Center    3,107.00                    
          Net capital accounts                        (476,888.60)                     
               The price (fair market value) allocated to each entity was              
          as follows:                                                                  








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