Illegal Activity
none
Blackmail
none
Date
Unknown
Document Type
other
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:41
Summary
This document details the tax implications for Limited Partners selling their interests in the Georgetown University Endowment's Access Fund. It covers capital gains, losses, tax basis adjustments, and limitations on deductibility of interest expense.
Metadata
- Subject
- Georgetown University Endowment Sale of Interests
- Sender
- —
- Recipients
- —
- Document ID
- DB-SDNY-0093656 SDNY GM_00239840
- Date
- —
Relationships 3
| Entity 1 | Relationship | Entity 2 | Description |
|---|---|---|---|
| Limited Partner | Financial | Access Fund | Limited Partner's sale of Interests in Access Fund |
| Access Fund | Agreement | General Partner | Partnership Agreement between Access Fund and General Partner |
| General Partner | Regulatory | IRS | General Partner's election under Section 754 of the Code requires IRS consent to revoke |
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
Transactions:
- Sale of Interests
- Distribution to Partners of cash or assets in-kind
Legal Compliance
- Potential tax implications related to the sale of interests in the Access Fund.
- Compliance with Section 754 of the Code regarding tax basis adjustments.
Raw Analysis JSON
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Themes
Financial transactions/money flowLegal matters/litigation
Organizations 3
Georgetown University EndowmentAccess FundIRS
Locations 1
U.S.
Text Analysis
- Tone
- Professional
- Purpose
- To explain the tax implications of selling interests in the Georgetown University Endowment's Access Fund.
- Significance
- This document outlines the tax consequences for limited partners selling their interests in the Access Fund, including potential gains, losses, and the impact of Section 754 elections.
File Info
- File Name
- EFTA01389301.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:41:50.185719
- DOJ Source
- View on DOJ