ASA Investerings Partnership, Alliedsignal Inc., Tax Matters Partner - Page 24

                                                    - 24 -24                                                      

             Mr. den Baas discussed ABN's specified return and the liquidation                                    
             of ASA.  Mr. den Baas provided AlliedSignal with a schedule                                          
             comparing Barber's and Dominguito's income allocations.  The                                         
             schedule indicated that from November 22, 1991, through April 30,                                    
             1992, Barber's and Dominguito's income allocations exceeded ABN's                                    
             funding costs by $152,162.  AlliedSignal prepared several                                            
             analyses regarding ABN's return.  Some of these analyses included                                    
             a determination of what ABN's return would have been if                                              
             AlliedSignal had made a $5 million payment "up-front" and if all                                     
             of Dominguito's interest in ASA had been redeemed by May 1992.                                       
             Based upon these analyses, AlliedSignal suggested that ABN pay                                       
             AlliedSignal $225,741, plus the $152,162 set forth in ABN's                                          
             schedule.  Ultimately, ABN agreed to pay AlliedSignal $315,000.                                      
                    On May 1, 1992, ASA tendered the AlliedSignal Short-Term                                      
             Notes to AlliedSignal, in return for a payment of $435 million                                       
             plus accrued interest of $1,646,522.  On the same day, ASA                                           
             purchased newly issued 30-year AlliedSignal notes (the                                               
             AlliedSignal Long-Term Notes).  The AlliedSignal Long-Term Notes                                     
             had a $480 million total notional principal amount and a 9.23                                        
             percent interest rate.  On May 20, 1992, ASA exchanged the                                           
             AlliedSignal Long-Term Notes for all the stock of ASA                                                
             Investments, Inc., a wholly owned subsidiary of ASA, which was                                       
             formed to participate in the liquidation of ASA.                                                     
                    On May 28, 1992, ASIC was liquidated into AlliedSignal and                                    





Page:  Previous  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  29  30  31  32  33  Next

Last modified: May 25, 2011