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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
unts of Special Limited Partners4) for the year will be reallocated to the capital accounts of Millennium Management as its "Incentive Allocation." The Net Capital Appreciation upon which the calculation of an Incentive Allocation is based is deemed reduced by the unrecovered balance, if any, in a Limited Partner's "Loss R
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
benefit of such Limited Partners) for the year will be reallocated to the capital accounts of Millennium Management as its "Incentive Allocation." The Net Capital Appreciation upon which the calculation of an Incentive Allocation is based is deemed reduced by the unrecovered balance, if any, in a Limited Partner's "Loss R
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
benefit of such Limited Partners) for the year will be reallocated to the capital accounts of Millennium Management as its "Incentive Allocation." The Net Capital Appreciation upon which the calculation of an Incentive Allocation is based is deemed reduced by the unrecovered balance, if any, in a Limited Partner's "Loss R
Entities connected to both Distributions of Property and The Net Capital Appreciation

the Cayman Islands
LOCATIONIndividual Limited Partners
ORGANIZATION
U.S. Treasury
ORGANIZATION
New York
LOCATIONCayman
LOCATIONKeogh
ORGANIZATIONDeductibility of Interest
ORGANIZATIONMillennium International, Ltd.
ORGANIZATION
New York State
LOCATION
United Kingdom
LOCATIONOptions and Special Allocations
ORGANIZATION
the University of Michigan
ORGANIZATIONMunger, Tolles & Olson LLP
ORGANIZATION
Millennium
ORGANIZATION
Luxembourg
LOCATION
Occidental College
ORGANIZATIONErnst & Young LLP
ORGANIZATION
Wilbur Ross
PERSONthe Delaware
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATION