Corporation Versus Partnership Ownership

[ETA Consulting LLC]

We know the basics when it comes to determining ownership of Corporations and Partnerships:
Ownership in corporations measure ownership in voting stock plus ownership in overall stock (voting and non-voting).  Meanwhile, ownership in partnerships measure the percentage of capital versus the percentage of profits.  

We also know that when measuring the non-voting shares in corporations, the value of the preferred stock may change depending on the ratio of the liquidation preference to the liquidation value of the company (where a higher liquidation preference would translate into a higher non-voting ownership); which can become pretty significant depending on the appraisal value of the company.

Here's my question:  How would such a liquidation preference translate in an LLC taxed as a partnership.  In theory, shouldn't it translate as an ownership of profits in the year of liquidation if (and only if) the company is actually liquidated?  Alternatively, would it somehow translate into a hypothetical value on the capital side; which would effective require an appraisal each year (depending on the amount of liquidation preference to the appraised value of the company)?

In all my years, I finally encountered a question that has me at my wits end 
 

[ETA Consulting LLC]

@Kevin C, @Larry Starr, @Tom Poje, @RatherBeGolfing, @Mike Preston.  I just learned how to 'mention' someone in a post.  Hope you don't mind.  Care to give thoughts on this?  This may be more of a Derrin Watson type of question, but wanted to see if there was something obvious that I may be missing. 

[Mike Preston]

Not a clue!  @ETA Consulting LLC Cool! Never used that before.

I would be reluctant to consider a contingent preference as ignorable.  That seems to me like not taking into account an option because it hasn't yet been exercised.  But options are typically analyzed with respect to corporations under 1563.  I don't know whether it makes sense to equate corporate options with liquidation preferences.  I agree that Derrin is likely your best bet.

[ETA Consulting LLC]

There appears to be very little (ZERO) Regulations on this issue.  It appears that the most conservative analysis would be to have to liquidation preference amount 'hypothetically' apply to the capital accounts where you assume the company is liquidated.  This invites the potential for a nightmare.  It would be nice of the liquidation preference amount was totally ignored.  I agree with the reluctance to consider it ignorable. 
I emailed Derrin hoping to get some additional insight. 

[RatherBeGolfing]

5 hours ago, ETA Consulting LLC said:

@Kevin C, @Larry Starr, @Tom Poje, @RatherBeGolfing, @Mike Preston.  I just learned how to 'mention' someone in a post.  Hope you don't mind.  Care to give thoughts on this?  This may be more of a Derrin Watson type of question, but wanted to see if there was something obvious that I may be missing. 

HA!  I have been thinking of asking Dave to add some sort of "ping" feature but it appears he already thought of it!