ASA Investerings Partnership, Alliedsignal Inc., Tax Matters Partner - Page 22

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             sale of the PPNs.  AlliedSignal filed a Form 1139 claiming a                                         
             $27,151,087 refund in 1987 attributable to a $181,628,283 net                                        
             capital loss carryback (i.e., some of which was attributable to                                      
             other capital gains and losses AlliedSignal incurred in 1990).                                       
             After the 1990 LIBOR note sale, ASIC held no LIBOR notes and                                         
             AlliedSignal held LIBOR notes with a total notional principal                                        
             amount of $280,810,000.  The total cost of selling the LIBOR                                         
             notes was $6,110,000, rather than Merrill Lynch's initial                                            
             estimate of less than $500,000.                                                                      
                    Merrill Lynch structured and entered into swap transactions                                   
             that transferred the interest rate risk of the LIBOR notes from                                      
             Generale Bank and Unibank A/S to Merrill Lynch.  These swaps were                                    
             an effective inducement for the banks to buy the LIBOR notes.  On                                    
             November 9, 1990, AlliedSignal entered into its sixth swap with                                      
             Merrill Lynch to further hedge its interest rate risk relating to                                    
             its LIBOR notes.  After this swap was in place, AlliedSignal was                                     
             hedged on 94 percent of its LIBOR notes.  On November 13, 1990,                                      
             AlliedSignal purchased 5-year Treasury futures to lock in                                            
             interest rates on the LIBOR notes it intended to sell later that                                     
             month.                                                                                               
             VIII.  Dominguito's Partnership Interest Is Reduced                                                  
                    On November 22, 1991, ASA redeemed 7.57 percent of                                            
             Dominguito's interest for $91,898,434.  The redemption reduced                                       
             Dominguito's interest to 33 percent and increased AlliedSignal's                                     





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