- 5 - On January 18, 2000, the remaining balance of the second option was unwound resulting in $79,208,185 received by Evergreen Trading with respect to which Evergreen Trading reported in its 2000 partnership tax return a gain of $38,378,419. A portion of such gain totaling $11,247,796 was allocated to petitioners’ respective flowthrough entities. During the latter part of March 2000, petitioners’ respec- tive flowthrough entities withdrew from Evergreen Trading and paid a 5-percent withdrawal fee of $159,302. When such entities withdrew from Evergreen Trading, each received a liquidating distribution of 192,602 Euros with a fair market value of $185,438. No other cash or property was distributed to petition- ers’ respective flowthrough entities (or to petitioners in these cases). On December 17, 2002, respondent issued a notice of begin- ning of administrative proceeding with respect to Evergreen Trading for the taxable year 1999, and on March 19, 2003, respon- dent issued such a notice with respect to Evergreen Trading for the taxable year 2000. On September 26, 2005, respondent issued a notice of final partnership administrative adjustment (FPAA) with respect to Evergreen Trading for the taxable years 1999 and 2000. In the FPAA that respondent issued with respect to Evergreen Trading for the taxable years 1999 and 2000, respondent made thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007