Saba Partnership, Brunswick Corporation, Tax Matters Partnership - Page 76




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              On its consolidated Federal income tax return for 1990,                 
         Brunswick reported a net short-term capital loss of $84,978,246              
         attributable to Saba.  The $84,978,246 net short-term capital                
         loss consists of the difference between Brunswick's purported                
         basis in the 3 LIBOR notes and the sales price of the notes, less            
         Brunswick's distributive share of the gain reported by Saba on               
         the sale of the Chase PPNs: ($123,613,031 - $26,601,451) -                   
         $12,033,334 = $84,978,246.                                                   
              Brunswick reported a loss on its audited and unaudited                  
         financial statements on the sale of the 3 LIBOR notes in the                 
         amount of $2,485,549, which is the difference between the cash               
         proceeds of $26,601,451 and the $29,087,000 value that Pepe                  
         assigned to the 3 LIBOR notes at the time that they were                     
         distributed.  The $2,485,549 loss was recorded in the portion of             
         Brunswick's Accrued Disposition Costs reserve account allocated              
         to partnership activity.  Brunswick's IPD and Tech Divestitures              
         Analysis of Deferred Disposition Costs account number 2107265                
         reflects the above $2,485,549 loss.                                          
              On its consolidated Federal income tax return for 1990,                 
         Brunswick reported Skokie’s distributive share of the gain                   
         reported by Saba on the sale of the Chase PPNs ($633,333) as                 
         other income, rather than capital gain.  If Brunswick had                    
         reported Skokie’s distributive share of the gain as capital gain             







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