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On July 13, 1990, Sodbury transferred the $92,452,227
received from Brunswick to ABN to be applied as a credit against
its loan account.
E. Brunswick-ABN Consulting Agreement
On July 3, 1990, Brunswick and ABN entered into an agreement
under which ABN agreed to provide consulting services to
Brunswick in exchange for a fee. Brunswick charged the fees that
it paid to ABN pursuant to the consulting agreement against the
portion of Brunswick's Accrued Disposition Costs reserve account
allocated to partnership activity. Brunswick paid ABN a total of
$750,000 pursuant to the consulting agreement: $250,000 on or
about July 10, 1990; $250,000 on or about February 26, 1991; and
$250,000 on or about February 27, 1992.
F. Payments on 4 LIBOR Notes
On July 2, 1990, Fuji and Norinchukin made timely LIBOR note
payments to Saba of $1,115,320.33 and $1,113,372.36,
respectively. Saba included $49,882 of these payments in its
interest income on its Form 1065 for the taxable year ended
March 31, 1991.
G. Distribution of 3 LIBOR Notes to Brunswick
On August 17, 1990, Saba distributed $24,016,789 in cash to
Sodbury, $266,853 in cash to Skokie, and 2 Fuji LIBOR notes and 1
Norinchukin LIBOR note to Brunswick. In notes dated August 17,
1990, Pepe valued the 3 LIBOR notes distributed to Brunswick by
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