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c. Partnership Assets in Each Category
In his written report, Mr. Burns includes a list of
partnership investments (and their values as of the valuation
date) by asset category. That list, as modified by the
aforementioned refinement of the “municipal bonds” category and
two additional classification changes13 (as well as the addition
of $2,000 to the “Cash and Money Market Funds” category to
reflect contributions by partners other than petitioner, see
supra note 8), yields the following profile of partnership assets
as of the valuation date:
Asset Type FMV Percentage
Cash & money market funds $883,622 44.0
U.S. Government bond funds 7,988 0.4
State & local bonds (MI) 41,750 2.1
Natl. Muni bond funds 101,145 5.0
Domestic equities 877,179 43.6
Foreign equities 98,686 4.9
Total $2,010,370 100.0
d. Date of Price/NAV Data
Both Mr. Dankoff and Mr. Burns obtain their closed end fund
data from tables prepared by Lipper Analytical Services (Lipper)
and published in Barron’s. However, Mr. Dankoff relies on data
as of October 24, 1997, while Mr. Burns utilizes data as of
13 Because “money market fund” is a term of art, see 17
C.F.R. sec. 270.2a-7(b) and (c) (1997), we have also reclassified
“Fidelity MI Muni Money Market” and “Short Term Income Fund-
Govt.” (listed by Mr. Burns as a municipal bond fund and a U.S.
Government bond fund, respectively) as money market funds, which
is how they are classified in brokerage statements introduced
into evidence.
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