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On September 28, 1992, UTP redeemed all of AlliedSignal's
preferred stock and warrants for $355 million. On November 18,
1992, in a secondary public offering, AlliedSignal tendered all
of its UTP common stock for $585 million. Thus, AlliedSignal
disposed of its entire interest in UTP for a total of $940
million.
On November 30, 1992, AlliedSignal sold its remaining LIBOR
notes to BFCE for $33,431,000. AlliedSignal calculated a basis
of $429,665,738 for these notes and on its 1992 Federal income
tax return, reported a capital loss of $396,234,738 on the sale.
AlliedSignal also reported a capital gain of $264,667,000 on the
sale of its UTP interest. After taking account of other capital
gains and losses, AlliedSignal had a net capital loss of
$144,741,887.
XII. Contribution, Distribution, and Expense Summary
AlliedSignal and ASIC contributed $110 million to ASA and
purchased Barber's and Dominguito's ASA interests for
$540,600,000 (i.e., a total investment of $650,600,000) and
ultimately received distributions from ASA totaling $712,678,500.
AlliedSignal made direct payments to Barber, Dominguito, and ABN
totaling $5,716,250; paid $47,872,343 in interest on the loan
from ASA; received $40,983,490 from its swap transactions; and
paid $24,783,800 of expenses relating to transaction costs (i.e.,
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