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transaction of $11,042,128. This amount was calculated as
follows:
Estimated total amount
received incident to
liquidation $3,498,052
Unrecovered prepaid
transportation advances ($10,517,364)
Inventory in pipeline (343,195)
Outstanding loan balance
(including accrued
interest, $48,026) (1,380,026)
Cost of capital stock (2,299,595)
Total (14,540,180)
Net loss reported (11,042,128)
Petitioner actually received $3,582,062 upon the liquida-
tion of Seaway because the final payments received in 1985
totaled $358,350, rather that the amount originally
estimated, $274,340. Petitioner's amount received from
the liquidation was calculated as follows:
Inventory in pipeline $343,195
Outstanding loan balance
(including $48,026 accrued
interest) 1,380,026
Recovery of unapplied prepaid
transportation charges--1984 1,500,491
Recovery of unapplied prepaid
transportation charges--1985 358,350
Total amount received 3,582,062
In the subject notice of deficiency, respondent
determined that the portion of the net loss attributable
to the cost of Seaway's capital stock, $2,299,595, is a
nonpatronage capital loss. The notice describes this
adjustment as follows:
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