Santa Monica Pictures, LLC, Perry Lerner, Tax Matters Partner - Page 60

                                        -145-                                         
               After the closing of the CDR transaction, Mr. Lerner, Mr.              
          Herz, and the law firm of Troy & Gould made efforts to confirm              
          the titles to the films and obtain physical elements for the                
          films.  We are unpersuaded, however, that these efforts amounted            
          to much more than window-dressing.  Mr. Peters testified that he            
          perceived Troy & Gould’s investigation to be abnormal considering           
          the age of the film titles, the original production cost of the             
          films, and the distressed nature of the companies that were the             
          source of the films.  He testified that although Troy & Gould’s             
          efforts might be completely appropriate with respect to other               
          kinds of films, they “might not be so appropriate” with respect             
          to the EBD film titles.                                                     
               Beyond its due diligence process, Troy & Gould and Mr. Herz            
          expended considerable effort to obtain facility and laboratory              
          access letters.  Those efforts extended into 1998, even after               
          Troy & Gould provided Mr. Lerner with its legal conclusions                 
          regarding the EBD film titles.  Given the nature of the                     
          particular film titles and Troy & Gould’s revelations, we are               
          unpersuaded that these efforts, too, were not mere window-                  
          dressing.                                                                   
               d.  Purported Interest in CDR Library                                  
               Petitioner also claims that he and Mr. Ackerman were                   
          interested in adding the 1,000-film CDR library to SMHC, and that           
          they thought that having an indirect interest in that company and           






Page:  Previous  135  136  137  138  139  140  141  142  143  144  145  146  147  148  149  150  151  152  153  154  Next

Last modified: May 25, 2011