Saba Partnership, Brunswick Corporation, Tax Matters Partnership - Page 107




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         Otrabanda's income from August 1, 1990, through June 21, 1991.               
         For tax purposes, Brunswick was allocated $2,587,763, Skokie was             
         allocated $67,040, and Bartolo was allocated $2,688,779 of                   
         Otrabanda's income from August 1, 1990, through June 21, 1991.               
         These differences were reported on Otrabanda’s Form 1065,                    
         Schedule M, for the period ended June 21, 1991.                              
              On June 21, 1991, Otrabanda was dissolved.  Otrabanda's                 
         partners received the following property in liquidation of their             
         interests in Otrabanda: (1) Brunswick received 99.265361541                  
         shares of OBC stock; (2) Skokie received .734638459 shares of OBC            
         stock plus cash of $741,778; and (3) Bartolo received cash of                
         $7,562,179.                                                                  
              On June 21, 1991, OBC held the following assets:                        
         Item                                               Amount                    
         Time deposits                                       $633,979                 
         Brunswick commercial paper                        39,856,500                 
         Non-Brunswick commercial paper                    26,787,631                 
         Accrued Interest--Brunswick commercial paper          15,375                 
         Accrued Interest--non-Brunswick commercial paper      24,152                 
         Accrued Interest from time deposits                      197                 
         Total                                            $67,317,834                 
         Brunswick treated OBC as part of its consolidated group on its               
         Federal income tax return for the fiscal year ended June 21,                 
         1991.  Brunswick did not report its receipt of, or any gain or               
         loss from, the 100 shares of OBC stock received from Otrabanda on            
         its Form 1120 for the 1991 tax year.                                         








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