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e. Tracinda owned 39,515,327 shares of UA (79.44 percent),
22,973,585 shares of TBS Preferred Stock (46.18 percent), and
$76,299,122 cash, which includes $64,533,655 ($9.18 per share)
cash paid in escrow by the Subscribing Public pursuant to
Tracinda's offering of UA shares.
f. Kerkorian owned 1,931,840 shares (3.88 percent) of TBS
Preferred Stock and $38,636,800 cash.
g. The MGM public shareholders owned 24,839,712 shares
(49.93 percent) of TBS Preferred Stock and $496,794,240 cash.
h. The Subscribing Public owned 7,029,810 shares (14.13
percent) of UA, for which they had paid $64,533,655 ($9.18 per
share).
i. UA executives owned 3,200,000 shares of UA (6.43
percent), for which they subsequently paid $28,800,000 to
Tracinda.
Discussion
A. Whether Summary Judgment Is Appropriate
Summary judgment is intended to expedite litigation and
avoid unnecessary and expensive trials. Northern Ind. Pub. Serv.
Co. & Subs. v. Commissioner, 101 T.C. 294, 295 (1993); Florida
Peach Corp. v. Commissioner, 90 T.C. 678, 681 (1988); Shiosaki v.
Commissioner, 61 T.C. 861, 862 (1974).
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