ude a Limited Partner whose contributions to the Partnership consisted solely of cash, the recharacterization rule described above would not apply. Tax Treatment of Partnership Investments In General. The Partnership expects to act as a trader or investor, and not as a dealer, with respect to its securities transactions. A trader and

contributions to the Partnership consisted solely of cash, the rule treating a distribution of property as a distribution of cash would not apply. Tax Treatment of Partnership Investments In General. Each of the Partnership and the Master Fund is engaged in a trade or business as a trader in securities and commodities. However, the P