Saba Partnership, Brunswick Corporation, Tax Matters Partnership - Page 90




                                       - 56 -                                         

         capitalization of $6,000.  Bartolo paid ABN Trust $28,338.94,                
         invoiced as a $25,000 fee for management, $3,335 for                         
         incorporation costs, and $3 in expenses.                                     
              On June 25, 1990, Clavicor Corporation, N.V. (Clavicor) was             
         incorporated in Curacao, Netherlands Antilles.  ABN Trust was the            
         sole managing director of Clavicor.  At the time that Clavicor               
         was incorporated, Rocky and Jasper each received one-half or                 
         3,000 shares of the 6,000 shares of Clavicor common stock                    
         authorized to be issued.  Each Clavicor share had a par value of             
         $1 for a total capitalization of $6,000.  Clavicor paid ABN Trust            
         $6,013, invoiced as a $3,500 fee for management, $2,500 in                   
         incorporation costs, and $13 in expenses.                                    
              On June 25, 1990, Rocky and Jasper transferred all 6,000                
         shares of Bartolo to Clavicor.  Bartolo was organized to serve as            
         a general partner in Otrabanda because ABN was not interested in             
         assuming the unlimited liability of a general partner and the                
         funding that ABN would provide to Bartolo could be syndicated.               
              C.  Otrabanda Organizational Meeting                                    
              By partnership agreement dated June 20, 1990, Brunswick,                
         Skokie, and Bartolo formed Otrabanda as a general partnership                
         under the laws of the State of New York.  The partners agreed                
         that Otrabanda would maintain its principal place of business in             
         Curacao, Netherlands Antilles.                                               







Page:  Previous  46  47  48  49  50  51  52  53  54  55  56  57  58  59  60  61  62  63  64  65  Next

Last modified: May 25, 2011