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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
ed in an investment in a Feeder Fund. Prospective investors should read Part One and Part Two of this Confidential Memorandum in their entirety and the Partnership Agreement of the Fund, as well as the organizational documents of the Feeder Fund in which they intend to invest and consult with their own advisers before deciding whet
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
d in an investment in a Feeder Fund. Prospective investors should read Part One and Part Two of this Confidential Memorandum in their entirety and the Partnership Agreement of the Fund, as well as the organizational documents of the Feeder Fund in which they intend to invest and consult with their own advisers before deciding whet
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
d in an investment in a Feeder Fund. Prospective investors should read Part One and Part Two of this Confidential Memorandum in their entirety and the Partnership Agreement of the Fund, as well as the organizational documents of the Feeder Fund in which they intend to invest and consult with their own advisers before deciding whet
Entities connected to both Distributions of Property and the Partnership Agreement of the Fund

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