- 27 -
As a second step, petitioner maintains that a liquidation of
all of IHCL’s assets at the end of 1991--the taxable year--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 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 1990,
the prior year. This increase consists of an additional $67,914 in
minimum gain chargebacks generated during 1991, plus partnership
income for 1991 of $1,490,387. The total minimum gain would first
be used to eliminate THEI’s negative capital account of $5,920,614.
The balance of $1,517,277 would be distributed in accordance with
the partnership agreement--that is, 99 percent to Dondi and 1
percent to THEI until June 20, 1991, when 100 percent would be
allocated to THEI.
Respondent’s figures, showing a comparison of the partners’
capital accounts that reflect minimum gain chargebacks, are as
follows:
Page: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 NextLast modified: May 25, 2011