ACM Partnership, Southampton-Hamilton Company, Tax Matters Partner - Page 105

                                       - 63 -                                         
          transactions with Merrill believed that they offered "very                  
          attractive", "extremely favorable" terms.  According to                     
          calculations performed by petitioner's expert Tanya Beder                   
          (Beder),16 the transactions effectively provided both banks with            
          funding at a cost 39 basis points lower than that available in              
          the direct interbank market.  The 39 basis points in savings                
          represents each bank's net present value gain from the structured           
          transaction expressed in relation to the amount of the financing            
          involved.  Beder's valuation analysis is useful for identifying             
          how the banks expected to gain overall while losing money on both           
          the basis and hedge swaps.                                                  
                            Valuation of the Positions of                             
                             BOT and BFCE as of 11/27/89                              
                                 ( $ millions = mm )                                  
                                                  BOT            BFCE                 
          LIBOR Notes                                                                 
               Price rec'd from ACM          $24.58 mm      $9.83 mm                  
               Mid-market value              (24.05)mm     (9.61)mm                   
          Citicorp Notes                                                              
               Price paid to ACM             (124.58)mm     (49.83)mm                 
               PV of expected sale proceeds                                           
               rec'd by banks                125.39 mm      50.15 mm                  
          Hedge Swap                                                                  
               Liability leg                 (24.88)mm     (9.77)mm                   
               Asset leg                     24.08 mm       9.62 mm                   
          Basis Swap                                                                  
               Asset leg                     18.77 mm       7.43 mm                   
               Liability leg                 (18.22)mm     (7.29)mm                   
               Merrill's cancellation option     (0.89)mm      (0.29)mm               

               16 Beder is affiliated with the New York consulting firm of            
          Capital Market Risk Advisors, and serves on the faculty of the              
          Yale School of Management.                                                  






Page:  Previous  53  54  55  56  57  58  59  60  61  62  63  64  65  66  67  68  69  70  71  72  Next

Last modified: May 25, 2011