- 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 gain
Page: Previous 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 NextLast modified: May 25, 2011