- 26 - those figures with substantial amounts of minimum gain chargebacks for both 1990 and 1991. As a first step, petitioner contends that if all of IHCL’s assets had been liquidated at the end of 1990--the year prior to the taxable year--the net liquidation proceeds would have been $16,328,755. This amount is computed as follows: Assets Cash $7,955,796 Unamortized organization costs 39,388 Investment in Pacific Gateway 2,328,218 Investment in Pacific Landmark (1,358,431) Liabilities (6,193) Subtotal 8,958,778 1990 Minimum gain chargeback 7,369,977 Distributable liquidation proceeds at book value 1/1/91 16,328,755 Petitioner contends that $5,920,614 of the minimum gain chargeback would be used first to eliminate THEI’s negative capital account. The $1,449,353 balance of the minimum gain chargeback would then be allocated pursuant to the IHCL Restated Agreement as it was in effect during 1990. Thus, 85 percent (or $1,231,959) would be allocated to THEI and 15 percent (or $217,404) would be allocated to Dondi. These allocations, when added to the partners’ capital accounts, yield a positive capital account of $1,231,959 for THEI and $15,096,769 for Dondi. Together, they reflect total partnership capital of $16,328,755--the amount of the previously identified liquidation proceeds.Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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