Saba Partnership, Brunswick Corporation, Tax Matters Partnership - Page 104




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         reported by Otrabanda on the sale of the IBJ CDs ($633,333) as               
         other income, rather than capital gain.  If Brunswick had                    
         reported Skokie’s distributive share of the gain as capital gain             
         on its consolidated Federal income tax return, Brunswick would               
         have reported a short-term capital loss attributable to Otrabanda            
         of $59,541,173.                                                              
              For financial reporting purposes, Brunswick reported a loss             
         of $1,703,173 on the sale of the 4 Sumitomo LIBOR notes.  The                
         $1,703,173 loss represents the difference between the cash                   
         proceeds of $17,458,827 from the sale and the $19,162,000 present            
         value that Merrill Lynch assigned to the Sumitomo LIBOR notes on             
         the date that they were distributed to Brunswick.  The $1,703,173            
         loss was recorded in the portion of Brunswick's Accrued                      
         Disposition Costs reserve account allocated to partnership                   
         activity.                                                                    
              G.  Partial Redemption of Bartolo's Partnership Interest                
         On December 4, 1990, Otrabanda held a partnership meeting                    
         and the partners agreed that the partnership would partially                 
         redeem Bartolo’s interest in the partnership.  On the same date,             
         Otrabanda distributed $46,370,431 in cash to Bartolo in                      
         redemption of a 35-percent partnership interest.  On December 4,             
         1990, Bartolo transferred the $46,370,431 plus $34,569 to                    
         Clavicor, and Clavicor transferred the full amount to ABN to be              
         applied as a credit against its loan account.                                





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