- 9 - through September 1986 included the accounts receivable that were listed in the assignment document. Petitioner did not send a letter notifying the account debtors of the execution of the assignment document, nor did petitioner file financing statements, as that term is defined in the Uniform Commercial Code. During the period the Euronotes were outstanding, petitioner engaged in no borrowing transactions in which any of its accounts receivable were pledged to an unrelated third party or otherwise subject to a security interest of an unrelated third party. The balance of the accounts receivable at all times relevant herein exceeded $28 million. Finance received annual interest payments in 1982, 1983, 1984, and 1985 in the amount of $12,775,000 from petitioner. Finance made annual interest payments in the amount of $12,075,000 in 1982, 1983, 1984, and 1985 to the holders of the Euronotes. Finance's aggregate income on the spread between the Euronote interest and the interest on petitioner's note was $2,800,000. In addition, Finance earned interest income on its investments (exclusive of interest paid by petitioner on its note). On October 10, 1985, petitioner repaid its note plus accrued interest and early payment premium to Finance. The payment consisted of $70 million in principal, $12,775,000 in interest for the period ending October 15, 1985, and a $1,050,000 call premium. On October 15, 1985, Finance redeemed the Euronotes byPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011