- 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 Next
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