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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
ully in the Third Amended and Restated Limited Partnership Agreement, as amended or supplemented from time to time (the "Partnership Agreement") of Millennium Partners, L.P. (the "Master Partnership") and elsewhere in this Confidential Memorandum. This summary should be read in conjunction with, and is qualified i
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
ully in the Third Amended and Restated Limited Partnership Agreement, as amended or supplemented from time to time (the "Partnership Agreement") of Millennium Partners, L.P. (the "Master Partnership") and elsewhere this Confidential Memorandum. This summary should be read in conjunction with, and is qualified in i
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
ully in the Third Amended and Restated Limited Partnership Agreement, as amended or supplemented from time to time (the "Partnership Agreement") of Millennium Partners, (the "Master Partnership") and elsewhere this Confidential Memorandum. This summary should be read in conjunction with, and is qualified in its e
Entities connected to both Distributions of Property and Millennium Partners

New York
LOCATION
U.S. Treasury
ORGANIZATIONCayman
LOCATIONthe U.S. Investment Company Act
ORGANIZATIONMillennium USA's
LOCATIONErnst & Young LLP
ORGANIZATIONThe Master Partnership's Organization
ORGANIZATIONKeogh
ORGANIZATIONMillennium International, Ltd.
ORGANIZATION
Millennium
ORGANIZATIONManagement of Millennium USA
ORGANIZATIONTrigger Event
ORGANIZATIONMaster-Feeder Relationship
ORGANIZATION
the Internal Revenue Service
ORGANIZATIONCapital Structure
ORGANIZATION
the Cayman Islands
LOCATION
United States
LOCATIONIndependent Public Accountants
ORGANIZATIONIndividual Limited Partners
ORGANIZATIONDeductibility of Interest
ORGANIZATION