FR EA

Extract to table

Pull the structured facts out of a document: parties, dates, amounts, obligations.

Extract to table / idr-4-response-org-syndication-costs.docx
idr-4-response-org-syndication-costs.docx · 1023-00003

Parties

HARKNESS LLP
Ironside Capital Management LP
Partnership Inc
Ironside Capital GP LLC
Capitol Statutory Services LLC
Greystone Fund Administration LLC
Costs Inc
Associates LLP

Dates

August 18, 2023
December 31, 2021
April 14, 2023
May 5, 2023
August 4, 2023
June 14, 2016
May 27, 2016
July 8, 2016
December 31, 2016
September 15, 2022

Amounts

$1,420,000
$5,000
$50,000
$680,000
$1,415,000
$3.82
$3.58
$412,000,000
$95,000,000
$175,000,000

Obligations

They must be permanently capitalized as part of the cost of raising capital
1995-279, the Tax Court examined the characterization of various formation-related expenses and emphasized that the determination must be based on the specific nature of the services rendered, rather than on broad, undifferentiated categorizations
The Treasury Regulations do not prescribe a specific allocation methodology; rather, the allocation must be reasonable and supported by contemporaneous documentation
Nothing in this response shall be construed as a concession, admission, or waiver of any right, claim, or defense, whether or not specifically addressed herein
To the extent that any document produced in connection with this response contains or reflects information that is subject to attorney-client privilege, work product protection, or any other applicable privilege, the production of such document is inadvertent, and such inadvertent disclosure shall not constitute a waiver of the applicable privilege with respect to the disclosed document or any other document or communication