Interhotel Company, Ltd. - Page 19




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               1   Respondent eliminated the unamortized organization costs;          
          thus, respondent’s figures for total assets and net proceeds are            
          $39,388 less than indicated above.  Without passing on the                  
          correctness of this omission, we have included these costs in order         
          to make respondent’s and petitioner’s figures more easily                   
          comparable.                                                                 
               Next, respondent contends that if all of IHCL’s assets had             
          been sold at the end of 1991, the proceeds therefrom would be               
          $10,449,135.  This amount is computed as follows:                           
               Assets                                                                 
               Cash                               $9,098,388                          
               Investment in Landmark             (3,967,304)                         
               Investment in Gateway              2,660,677                           
               Note receivable from THEI          2,619,833                           
               Unamortized organization costs     39,388                              
               Total assets             10,450,982                                    
               Liabilities                                                            
               Accounts payable                   (1,847)                             
               Total liabilities                 (1,847)                              
               Net proceeds                       10,449,135                          
               Respondent asserts that, at the end of the first year (1990)           
          all the liquidation proceeds would have gone to Dondi, which was            
          the only partner to have a positive capital account. Further,               
          respondent claims the amount available for distribution upon                
          liquidation is $5,960,002 less than the positive capital account            
          balance of $14,879,392 for Dondi.                                           
               At the end of the next year (1991, the year involved herein),          
          the net book value of IHCL’s assets was $10,449,135.  Respondent            
          contends that under the IHCL Restated Agreement, all of the                 
          increase in book value would have been distributed to Mr.                   





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