ACM Partnership, Southampton-Hamilton Company, Tax Matters Partner - Page 89

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          3-week period since the issuance of the LIBOR Notes, which caused           
          them to lose value.                                                         
          6.  Tax and Financial Accounting for the Results                            
               For Federal income tax purposes, ACM treated the sale of the           
          Citicorp Notes as a contingent payment sale, governed by section            
          15a.453-1(c)(3), Temporary Income Tax Regs., 46 Fed. Reg. 10714             
          (Feb. 4, 1981).  As there was no stated maximum selling price and           
          all payments on the LIBOR Notes would be received over a fixed              
          period of 6 taxable years, ACM recovered its basis in the                   
          Citicorp Notes ratably over 6 years.  On Form 1065, U.S.                    
               Partnership Return of Income, for FYE 11/30/89, the                    
          partnership reported capital gain of $110,749,239.10  The gain              
          was allocated among the partners in proportion to their capital             
          accounts as shown on the November 30, 1989, revaluation                     
          worksheet:  $91,516,689 to Kannex, $18,908,407 to Southampton,              
          and $324,144 to MLCS.  The parties to this proceeding have agreed           
          that the partnership's tax basis in the LIBOR Notes immediately             
          after the sale was $146,253,803, an amount that exceeded the cost           
          of the Notes by the gain recognized on the sale.                            


               10 ACM computed the gain as follows:                                   
               Payments received in FYE 11/30/89        $140,000,000                  
               Basis recovered in FYE 11/30/89                                        
                    Citicorp Note basis plus                                          
                    accrued interest         175,504,564                              
                    Portion allocable to                                              
                    FYE 11/30/89 (1/6)                     (29,250,761)               
               Capital gain                                110,749,239                




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