ACM Partnership, Southampton-Hamilton Company, Tax Matters Partner - Page 101

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          approximately one-half of the overall decline in long-term debt             
          during this year.  As of December 31, 1991, the value of                    
          Southampton's and Colgate's capital accounts plus the proceeds              
          that had been received from sale of BFCE LIBOR Notes exceeded the           
          costs of their combined investment in the partnership by                    
          approximately $5.42 million, representing a pre-tax internal rate           
          of return of 4.7 percent.  More than 2 percentage points of this            
          return was attributable to the appreciation of the partnership's            
          Colgate debt caused by further declines in interest rates in the            
          month following Kannex's redemption.                                        
          8.  Merrill's Collateral Swap Transactions                                  
               The origination and remarketing costs of nearly $2 million             
          that Colgate incurred through its partnership strategy                      
          represented the costs of a highly complex structure of collateral           
          swaps arranged and executed by Merrill for the purpose of                   
          accommodating the investment in and divestment of assets                    
          qualifying for contingent payment sale treatment.  This section             
          outlines the transactions that Merrill entered into with BOT,               
          BFCE, and Sparekassen between the issuance of the LIBOR Notes in            
          November 1989 and the partnership's sale of the BOT LIBOR Notes             
          in December 1991.                                                           



               13(...continued)                                                       
          1991 owing to a scheduled principal payment ($12.5 million).                






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