Saba Partnership, Brunswick Corporation, Tax Matters Partnership - Page 60




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         Brunswick's financial adviser regarding Saba in exchange for a               
         fee of $500,000.  Brunswick paid Merrill Lynch's fee on April 4,             
         1990.                                                                        
              By partnership agreement dated February 23, 1990, Brunswick,            
         Skokie, and Sodbury formed Saba as a general partnership under               
         the laws of the State of New York.  The partners agreed that Saba            
         would maintain its principal place of business in Curacao,                   
         Netherlands Antilles.  The partnership agreement stated that the             
         partnership was being formed "for the object and purpose of                  
         making investments in notes, bonds, debentures, and other                    
         interest bearing instruments, owning, managing and supervising               
         such investments, sharing the profits and losses therefrom, and              
         engaging in such activities necessarily incidental or ancillary              
         thereto."  The partnership agreement further stated that                     
         generally each item of partnership income, gain, expense, and                
         loss for each fiscal year would be allocated among the partners              
         in proportion to each partner's capital account.  However, if a              
         partner's proportionate interest in partnership capital were to              
         change during any fiscal year, the partnership's books would be              
         closed as of the date of such a change and partnership income,               
         gain, expense, and loss would be allocated to the partners in                
         proportion to their respective capital accounts as determined                
         immediately prior to such change.  The partnership agreement                 
         stated that a partner would be permitted to request in writing               





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