Saba Partnership, Brunswick Corporation, Tax Matters Partnership - Page 116




                                       - 82 -                                         
         effort to determine the potential profitability of an investment             
         in the LIBOR notes at issue.  Relying on a market-based forecast             
         for 3-month LIBOR as of February 23, 1990 and June 20, 1990,                 
         Smith opined that the LIBOR notes had the potential to provide               
         returns up to $10,826,000 over their 5-year terms.  Relying on               
         the "symmetric" theory of interest rate behavior--the theory that            
         a 525 basis point increase in interest rates was as equally                  
         probable as the actual 525 basis point decrease in interest rates            
         that occurred during the period in question--Smith opined that               
         the LIBOR notes had the potential to provide returns of up to                
         $40,487,000.  Relying on the "equal probability" theory of                   
         interest rate behavior--the theory that the likelihood of                    
         interest rates falling by one-half is equal to that of interest              
         rates doubling over the same period--Smith opined that the LIBOR             
         notes had the potential to provide returns of up to $80,683,000              
         over their 5-year terms.                                                     
         Respondent retained Richard W. Leftwich (Leftwich),                          
         Professor of Accounting and Finance at the University of Chicago             
         Graduate School of Business, to serve as an expert witness in                
         these cases. Leftwich believed that Smith's market-based forecast            
         for 3-month LIBOR was too high based on prevailing market rates              
         and forecasts.  Leftwich further opined that, in assessing the               
         market's forecast of future interest rates, Smith improperly                 
         ignored the impact of the so-called liquidity and risk premium               






Page:  Previous  72  73  74  75  76  77  78  79  80  81  82  83  84  85  86  87  88  89  90  91  Next

Last modified: May 25, 2011