iquidation value of the Preferred Units will be treated as transferred to the Residual Unit holders, potentially resulting in a taxable gift to the Residual Unit holders in that amount. Caution dictates that Preferred Unity holders should file the election to treat preferred payments as made on their respecti

the interest in question, including, but not limited to: (i) the potential for distributions to the interest - the more likely that a holder of a Residual Unit will receive distributions, the lower the relative discount since distributions are generally viewed as important to a holder of a closely-held inv