- 6 - The Bill Of Sale for the movie “Summer Lovers” was executed by Filmways on July 14, 1982. SLA executed a $6,540,000 non- negotiable recourse promissory note to Filmways, and Filmways issued a receipt for $6,540,000 on the same date. C. Partnership Tax Return On its 1982 Form 1065, U.S. Partnership Return of Income, SLA reported that its business commenced on January 1, 1982. On Form 4562, Depreciation and Amortization, SLA reported 5-year property (the film) being placed in service on January 1, 1982. The property was reported to have a basis of $6.6 million and SLA took a full year’s depreciation deduction in the amount of $990,000. An opinion letter was issued by the law firm of Goldschmidt, Fredericks & Oshatz as to tax consequences of the formation and operation of SLA. The opinion letter stated, in part, “The General Partners have advised that the Partnership will claim a full year’s depreciation for 1982. * * * [t]he Partnership will have been in existence for all of 1982, so that it will have a 12 month taxable year”. A report on the projected tax basis and cash-flow was prepared by the accounting firm of Touche Ross & Co. on May 23, 1982. In reviewing the depreciation of the film the report stated, in part, that “The general partners believe that the Partnership has actively been engaged in business from January 1, 1982 through the present.”Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011