Saba Partnership, Brunswick Corporation, Tax Matters Partnership - Page 102




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              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.                                                                











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