- 42 - 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 gainPage: Previous 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 Next
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