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by reducing the amount of short-term capital loss recognized during the tax year in which it receives its liquidating distribution upon withdrawal. Distributions of Property. A partner's receipt of a distribution of property from a partnership is generally not taxable. However, under Section 731 of the Code, a distribut
e inunediately preceding Accounting Period: each Accounting Period shall close at the close of business on the first to occur of (i) the last day of Millennium USA's fiscal quarter (which shall be the calendar quarter). (ii) the date immediately prior to the effective dale of the admission of a new• Partner pursu
by reducing the amount of short-term capital loss recognized during the tax year in which it receives its liquidating distribution upon withdrawal. Distributions of Property. A partner's receipt of a distribution of property from a partnership is generally not taxable. However, under Section 731 of the Code, a distributi
stimates and assumptions that the Millennium Management Group believes are reasonable and appropriate, but which may be imprecise and may result in Millennium USA's bearing a larger portion of such expenses than if they were calculated in a different manner. Assets of the Millennium Management Group, including,
by reducing the amount of short-term capital loss recognized during the tax year in which it receives its liquidating distribution upon withdrawal. Distributions of Property. A partner's receipt of a distribution of property from a partnership is generally not taxable. However, under Section 731 of the Code, a distributi
stimates and assumptions that the Millennium Management Group believes are reasonable and appropriate, but which may be imprecise and may result in Millennium USA's bearing a larger portion of such expenses than if they were calculated in a different manner. Assets of the Millennium Management Group, including,
Entities connected to both Distributions of Property and Millennium USA's

U.S. Treasury
ORGANIZATION
New York
LOCATION
Millennium
ORGANIZATIONCayman
LOCATIONMillennium International, Ltd.
ORGANIZATIONThe Master Partnership's Organization
ORGANIZATIONMillennium Partners
ORGANIZATION
the Internal Revenue Service
ORGANIZATIONErnst & Young LLP
ORGANIZATIONKeogh
ORGANIZATIONManagement of Millennium USA
ORGANIZATION
United States
LOCATIONTrigger Event
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATIONIndependent Public Accountants
ORGANIZATIONMaster-Feeder Relationship
ORGANIZATION
the Cayman Islands
LOCATIONCapital Structure
ORGANIZATIONMillennium USA LP
ORGANIZATIONIndividual Limited Partners
ORGANIZATION