- 46 -
through June 21, 1991. For tax purposes, Brunswick was allocated
$190,177, Skokie was allocated $1,744, and Sodbury was allocated
$21,325 of Saba's income from April 1, 1991 through June 21,
1991. These differences were reported on Saba’s Form 1065
(Schedule M) for the period ended June 21, 1991.
Saba's partners received the following property in
liquidation of their Saba partnership interests: (1) Brunswick
received Saba's 100 shares of SBC stock; (2) Skokie received
$811,541 in cash; and (3) Sodbury received $9,918,840 in cash.
On June 21, 1991, Sodbury's loan account with ABN was
credited in the amounts of $4,946,172.46 and $2,000,000.
Brunswick filed SBC's Federal income tax return for the
period April 3, 1991 through June 21, 1991, reporting taxable
income of $1,054,460 and tax due of $358,516. Brunswick paid the
tax due. Brunswick included SBC on its consolidated Federal
income tax return for 1991. Brunswick did not report its receipt
of, or any gain or loss from, the 100 shares of SBC stock that it
received upon Saba's dissolution.
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