After a mere six years of blood, sweat and tears, you made partner in your accounting firm, Smart & Smarter, LLP. You made your initial capital contribution of $250,000 on January 1, Year A, and in exchange received a .4% equity inter-est in the partnership. Here are some additional facts:

• Smart & Smarters Year A partnership return, Form 1065, reported ordin-ary business income of $160,096,336. Smart & Smarter distributed an ag-gregate total of $142,834,019 cash to its partners during the year.

• Smart & Smarters Year B Form 1065 reported ordinary business income of $180,440,025. Smart & Smarter distributed an aggregate total of $165,316,650 cash to its partners during the year.

• Oops! Smart & Smarters Year C Form 1065 reported a net operating loss of $22,090,046. Nevertheless, Smart & Smarter distributed an aggregate total of $126,960,260 cash to its partners during the year.

If all allocations and distributions from Smart & Smarter to its partners during or for those three years were pro rata, what is your adjusted basis in your partner-ship interest at January 1, Year D?