- 43 - on its consolidated Federal income tax return, Brunswick would have reported a short-term capital loss attributable to Saba of $84,344,913. I. Partial Redemption of Sodbury's Partnership Interest On September 14, 1990, Saba distributed $60,204,145 in cash to Sodbury in redemption of a 35-percent partnership interest. For purposes of determining the amount to be distributed in the redemption, Pepe valued the remaining Norinchukin LIBOR note held by Saba at $9,680,000. The $9,680,000 amount included a $375,000 private placement discount (25 percent of the original $1,500,000 private placement discount) and $133,750 (25 percent of the unidentified $535,000 "fee"). After the September 14, 1990 distribution, Brunswick held a 89.181882-percent partnership interest in Saba, Skokie held an .8181818-percent partnership interest, and Sodbury held a 10- percent partnership interest. On September 14, 1990, Sodbury transferred the $60,204,145 that it received from Saba to ABN to be applied as a credit against its loan account. J. Payments on Norinchukin LIBOR Note Norinchukin made timely payments to Saba on the remaining LIBOR note between October 1990 and April 1991. Saba amortized the LIBOR note payments for tax purposes and reported imputed interest as follows:Page: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 Next
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