2002 Ruling 2002-0140733 - XXXXXXXXXX - Sequential Butterfly -- summary under Distribution

sequential butterfly. In each butterfly, "to the extent a portion of the cash or near cash property of the [DC] Group is committed by the [DC] Group in order to fund the acquisition of a business property (that is to be acquired regardless of the Proposed Transactions), such cash or near cash property will be classified as business property." (para.52(g) and 73(f)) "[T]he net FMV of all accounts receivable, inventory and prepaid expenses of [DC]'s that are initially classified ...as cash or near cash property that will relate to a business that will be carried on by the [TC Groups] and that will be collected or consumed in the ordinary course of such business, will then be reclassified as business property...." (para. 53(a)(ii) and (b)(ii)), 62(a)(ii) and (b)(ii))