- 68 - D. Payments on LIBOR Notes On November 1, 1990, Sumitomo made a timely payment of $1,085,255.84 to Otrabanda on the LIBOR notes. Otrabanda amortized this payment for tax purposes and reported $23,907 of the payment as imputed interest on its Form 1065 for the taxable year ended June 21, 1991. E. Distribution of LIBOR Notes to Brunswick On November 1, 1990, Otrabanda distributed $354,523 in cash to Skokie, $15,968,064 in cash to Bartolo, and the 4 Sumitomo LIBOR notes to Brunswick. The partners relied on Pepe to determine the value of the Sumitomo LIBOR notes. Pepe assigned a value of $19,162,000 to the Sumitomo LIBOR notes, inclusive of the $750,000 private placement discount on the sale of the IBJ CDs. By valuing the Sumitomo LIBOR notes in this fashion, Bartolo was relieved of the cost or private placement discount associated with the sale of the IBJ CDs. On November 1, 1990, Bartolo transferred $16,100,000 to Clavicor, including the $15,968,064 received in the Otrabanda distribution. On November 1, 1990, Clavicor transferred $16,083,986 of the $16,100,000 to ABN to be credited against its loan account.Page: Previous 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 Next
Last modified: May 25, 2011