- 101 -
On Schedule D of its 1998 partnership tax return, SMP
reported its sale of $81,590,418 (face value) notes receivable.
As described in more detail supra, SMP reported a long-term
capital loss of $80,190,418 on this sale.
B. Corona
Following an extension to October 15, 1998, Corona filed its
1997 partnership tax return (for the period December 16, 1997, to
December 31, 1997), which it dated October 14, 1998. Corona
reported Mr. Lerner, Peridon, SMP, and Imperial as having varying
interests in Corona’s profits, losses, and ownership of capital.
Corona reported Mr. Lerner as its tax matters partner.
Corona reported a $79,912,955 basis in the $79 million
receivable. As described in more detail supra, on Schedule D of
its 1997 partnership tax return Corona reported selling this
receivable for a long-term capital loss of $78,768,955.
C. Mr. and Mrs. Ackerman
Peter and Joanne Ackerman filed joint Federal income tax
returns for 1997 and 1998. On their 1997 return, the Ackermans
reported a net long-term capital loss from SMP of $213,715,813
and a net short term capital loss from SMP of $11,545,023.
Among other gains and losses, the $213,715,813 net long-term
capital loss included these items: a $147,486,000 loss that
flowed through from SMP to Somerville S Trust to the Ackermans
when SMP sold the $150 million receivable in 1997; a $62,237,061
Page: Previous 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 NextLast modified: May 25, 2011