- 67 -
APPENDIX C
Computation of Curtis’s Share of Countryside LP (Countryside) Liabilities
and Curtis’s Basis in His Countryside Interest Immediately Before the 12/26/00 Distribution
I. Computation of Curtis’s share of Countryside liabilities and Curtis’s basis in his Countryside interest as of 1/1/00
A. As of 1/1/00, Curtis’s share of Countryside liabilities was $4,402,714. See (1) below.
B. As of 1/1/00, Curtis’s basis in his Countryside interest was $3,798,080. See (2) below.
Basis at start
of period Contributions/(distributions)of money during period Taxable income/(loss)for period1 of liabilities for periodIncrease/(decrease) in shareBasis at end
of period
Year
1993 -0- $198 ($9,325) $3,546,894 $3,537,767
1994 $3,537,767 -0- (113,954) 869,828 4,293,641
1995 4,293,641 -0- (97,825) 13,449 4,209,265
1996 4,209,265 -0- (41,702) (115,511) 4,052,052
1997 4,052,052 (60,000) (62,658) (71,564) 3,857,830
1998 3,857,830 (30,000) (8,634) (30,695) 3,788,501
1999 3,788,501 (49,725) (131,009) 190,313 3,798,080 (2)
Total 4,402,714 (1)
1 For 1993 through 2000, there was no partnership tax-exempt income and no nondeductible partnership expenditures as
described in sec. 705(a)(1)(B) and (2)(B).
II. Events from 1/1/00 until immediately before the 12/26/00 distribution affecting Curtis’s share of Countryside
liabilities and Curtis’s basis in his Countryside interest
A. Curtis’s share of Countryside liabilities immediately before the 12/26/00 distribution
$4,402,714 Curtis’s share of liabilities as of 1/1/00
1,003,562 Increase in share of liabilities attributable to transfer of a 5-percent interest. See (1) below.
2,120,400 Curtis’s share of the Countryside-CB&T $8,550,000 liability. See (2) below.
837,481 Curtis’s share of the MP’s $3,445,506 of liabilities. See (3) below.
8,364,157 Curtis’s share of Countryside liabilities immediately before the 12/26/00 distribution
(1) On 6/29/00, Curtis acquired a 5-percent interest in Countryside from Countryside
partner Winn. This transfer increased Curtis’s percentage interest
in Countryside from 19.8 percent to 24.8 percent. The transfer resulted in a
$1,003,562, increase in Curtis’s share of Countryside liabilities, computed as Winn’s
$14,892,855 share of Countryside liabilities as of Jan. 1, 2000, multiplied by 5/74.2.
(2) In October 2000, Countryside borrowed $8,550,000 from Columbus Bank & Trust Co. (CB&T).
Curtis’s 24.8-percent share of this liability was $2,120,400.
(3) In October 2000, Manchester Promisee L.L.C. (MP) borrowed $3,400,000 from CB&T. In addition,
on 12/26/00, MP had accrued $45,506 of unpaid interest expense. Immediately before
the 12/26/00 distribution, Countryside owned 99 percent of CLP Promisee L.L.C. (CLPP)
which, in turn, owned 99 percent of MP. Therefore, Countryside’s share of MP’s
liabilities was $3,376,940. Curtis’s share of Countryside’s share of this liability
Page: Previous 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 Next
Last modified: March 27, 2008