Illegal Activity
none
Blackmail
none
Date
Unknown
Document Type
other
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:43
Summary
This document describes the tax implications for Limited Partners selling their interests in the Access Fund. It covers topics such as capital gains, losses, tax basis adjustments, and limitations on deductibility of interest expense.
Metadata
- Subject
- Sale of Interests
- Sender
- —
- Recipients
- —
- Document ID
- DB-SDNY-0088359 SDNY GM_00234543
- Date
- —
Relationships 2
| Entity 1 | Relationship | Entity 2 | Description |
|---|---|---|---|
| Limited Partner | financial | Access Fund | Limited Partner's share of Access Fund liabilities |
| General Partner | legal | Partners | General Partner makes election under Section 754 of the Code to adjust the tax basis of its assets upon the sale or other disposition of Interests or upon the distribution to Partners of cash or assets in-kind |
Notable Quotes 2
A Limited Partner generally will recognize capital gain or loss on the sale of Interests, except for any gain attributable to unrealized receivables or inventory• items (which arc broadly defined for this purpose) held by the Access Fund at the time of the sale.
The Partnership Agreement generally prohibits transfers of Interests without the consent of the General Partner.
Financial Information
Amounts:$250,000
Assets:
- Interests
- Unrealized receivables
- Inventory items
- Cash
- Assets in-kind
- Property
Transactions:
- Sale of Interests
- Distribution to Partners of cash or assets in-kind
- Transfers of interests in that Fund
- Distributions of cash or property to a partner
Raw Analysis JSON
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Themes
Financial transactions/money flowLegal matters/litigation
Organizations 3
SOUTHERN FINANCIAL LLCAccess FundIRS
Locations 1
U.S.
Text Analysis
- Tone
- Professional
- Purpose
- To explain the tax implications of selling interests in the Access Fund.
- Significance
- This document outlines the tax implications for Limited Partners selling their interests in the Access Fund, including potential gains, losses, and adjustments to tax basis.
File Info
- File Name
- EFTA01386597.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:43:14.520559
- DOJ Source
- View on DOJ