Tuesday, August 21, 2007

Sorry about the lack of updates since Friday. Sunday was my 7th anniversary to the TaxBabe and yesterday was pure hell at work (f*cking laptop crashed in the middle of the day). Anyway... here you go

The Baseball Update

Wow. What a whirlwind last few days. Friday night was a rollercoaster. Encouraging that the Sox are managing to hit a bit more "in the clutch", or at least late (which makes the stupid 1-41 stat so ridiculous). Still - Gagne was bad and had a little bad luck. The Guerrero base hit was off a good pitch - that guy is just a monster and routinely hits balls off his shoetops. The other hits, however, were on lame fastballs that didn't move and offspeed stuff that stayed too high in the zone. He's still not locating consistently. The rest of the weekend was a bit of a letdown as the Yanks climbed back to within 4.

Last night, I could only listen to the Sox at work, but watched the Yankees. Three Things I Noticed: (1) Glenn Gefner is a freaking baby - apparently spooked out by a mouse in the Trop press box last night, his voice went about three pitches higher the rest of the game. What's really annoying about him though is that he does not appear to be connected to the game or to Castiglione at all. This piece at Sox and Dawgs.com makes the point much more insightfully than I can, but I have to say (again) that I actually miss The Trup. (2) Lowell keeps proving my point. Big hit after big hit. (3) The Yankees pen still is their achilles heel. They put 6 on the board and lose with Sean Henn in a high leverage situation. For all the talk about how great it is that the Yanks are promoting from within (Hughes, Chamberlain, Ramirez), but does anyone think any of those guys will be in high leverage situations in the postseason? No. It's Rivera, Farnsworth and pray for the ghost of Mike Stanton (circa '98-'00). It's admirable that the Yanks are bringing Chamberlain along slowly, but let's not all go blanking each other's blanks just yet, Yankees fans.

Blogs du jour: Blood Sox echoing my point regarding Lowell. Wouldn't go so far as to call him the MVP, but it could be close (Pedroia, Lowell, Ortiz, Papelbon, Beckett).

Fire Brand of the AL reports on the PTBNL that the Sox received for Wily Mo. Welcome to Boston, Chris Carter.

More on Gefner at 38cliches.com.

The Taxes Update

Again, not much in the world of taxes to report on. Well, one that is also part of the death update (see below). I have an interesting puzzle here at work though...

Partner in partnership has bargained for a preferred equity investment that returns capital plus an 8% accruing preferred return. On liquidation, partner is entitled to greater of 1.5x capital or capital + accrued preferred return. Partner gets this return regardless of profits (i.e., can receive it out of other partners' capital if the investment goes sideways or goes down).

The obvious concern is capital shift - in two respects - first, a portion of the other investors' capital is arguably being shifted on an annual basis as the preferred return accrues. Second, is that on a hypothetical liquidation analysis, preferred partner would be entitled to 1.5x its investment, regardless of profits.

Partner does not want to have a capital shift today to it. So, one could characterize the 1.5x return as first coming out of profits of the venture, but to the extent there are insufficient profits, it will receive a 707(c) guaranteed payment for the difference. The guaranteed payment ideally will not be includible until liquidation (or at least some later time when the partnership will deduct it).

Concerns that the 707(c) payment is just recharacterized as a distribution preference, which could force a capital shift, but at least it's a position.

The Death Update

Big death over the weekend was Leona Helmsley. The obit is here.

And a great piece by the Taxgirl is here. Check it out. I particularly like the Queen of Spades playing card. Looks like it's right out of the Saddam deck of cards.

1 comment:

LC said...

Jay. Thanks for the mention of 38cliches.com