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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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