ASA Investerings Partnership, Alliedsignal Inc., Tax Matters Partner - Page 18

                                                    - 18 -18                                                      

             the PPNs and reported $539,443,361 of capital gain on the sale                                       
             (i.e., $681,300,000 minus $141,856,639).  The gain was allocated                                     
             among the partners as follows:                                                                       
                                              Percentage                                                          
                                             Interest in ASA                        Gain                         
             ASIC                                    1                          $5,394,434                        
             AlliedSignal                     9                                 48,531,902                        
             Barber                           36                         194,199,610                              
             Dominguito                           54                            291,299,415                       
             Total                            100                        539,425,361                              
             The installment payments would be received on the LIBOR notes                                        
             over 5 additional partnership taxable years (i.e., May 31, 1991,                                     
             through May 31, 1995).                                                                               
             V.  AlliedSignal Purchases Majority Interest in ASA                                                  
                    On August 2, 1990, AlliedSignal issued $435 million of                                        
             commercial paper.  On the same day AlliedSignal purchased an                                         
             additional interest in ASA for $545 million.  AlliedSignal                                           
             purchased 36 percent of ASA from Barber for $397,438,000 and                                         
             13.43 percent of ASA from Dominguito for $147,562,000.  The $545                                     
             million AlliedSignal paid consisted of a $540,600,000 payment                                        
             equal to the value of Barber's and Dominguito's interest (i.e.,                                      
             49.43 percent of $1,093,657,933) and a $4,400,000 premium                                            
             payment.  AlliedSignal paid the $4,400,000 to compensate for the                                     
             shortfall between ABN's specified return and Barber's and                                            
             Dominguito's income allocations.  After these purchases, the ASA                                     
             interests held by AlliedSignal, ASIC, Barber, and Dominguito were                                    
             58.43 percent, 1 percent, 0 percent, and 40.57 percent,                                              




Page:  Previous  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  Next

Last modified: May 25, 2011