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loss that flowed through from SMP to Somerville S Trust to the
Ackermans when SMP sold 79.2 percent of its interest in Corona in
1997; and a $4,097,577 loss that flowed through from Corona to
SMP to Somerville S Trust to the Ackermans when Corona sold the
$79 million receivable in 1997.71
The $11,545,023 net short-term capital loss flowed through
from SMP to the Ackermans when SMP sold 14.65 percent of its
interest in Corona to Imperial in 1997.72
On their 1998 return, the Ackermans reported a net long-term
capital loss from SMP of $80,190,418, which flowed through from
SMP to Somerville S Trust to the Ackermans when SMP sold the $81
million receivable to TroMetro in 1998.73
71 On its 1997 return, SMP reported a net long-term capital
loss of $213,715,689 on Schedule D, Capital Gains and Losses.
From this amount, SMP passed through net long-term capital gains
of $62 to Mr. Lerner and $62 to Rockport Capital, and a net long-
term capital loss of $213,715,813 to Somerville S Trust.
72 The sale of the 14.8-percent interest in Corona resulted
in a $11,647,367 loss on SMP’s 1997 tax return. SMP reported a
net short-term capital loss of $11,544,902. From this amount,
SMP passed net short-term capital gains of $60 to Mr. Lerner and
$61 to Rockport Capital and a short-term capital loss of
$11,545,023 to Somerville S Trust.
73 On Schedule D of its 1998 return, SMP reported a net
long-term capital loss of $79,979,011; however, it passed through
a net long-term capital loss of $80,190,418; i.e., the entire
amount of the loss that it reported on the sale of the $81
million receivable. SMP reported $211,407 as its share of net
long-term capital gain from other partnerships, estates, and
trusts. SMP failed to pass this amount through to its members
via Sch. K, Partners Share of Income, Credits, Deductions, etc.
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