UNG Qualify In Uverylhing We Do Page 1 EFTA00605877 Recognition of Tufts Gain in Exchanges Sale of 7.5% of Interests and Recognition of 7.5% of Tufts Gain LB (Amounts in Millions) MR JH Total Equity Cash Proceeds ($22/unit) $152.0 $96.7 $96.7 $345.4 Cash Taxes on Equity Proceeds (35% effectiv

ransfer of an interest, but in the AP Professional Holdings LPA, the partnership will make a 754 election if directed by the general partner. HI. Tufts Gain Tax Treatment The transfer of the interests in the Partnerships that occurs at the time of Mr. Black's death could result, pursuant to Section 75