Santa Monica Pictures, LLC, Perry Lerner, Tax Matters Partner - Page 93

                                        -175-                                         
          these preferred distribution rights and claims that the existence           
          of these rights denotes some economic incentive on the part of              
          the banks to stay in SMP.  Nonetheless, these preferred                     
          distribution rights parallel, almost precisely, the terms of the            
          contingent put price for the banks’ preferred interests.  They              
          afforded the banks no additional advantage from remaining in the            
          SMP partnership rather than exercising their put rights on                  
          December 31, 1996--in either case, the banks would receive                  
          whatever value might be realized on any liquidation of the                  
          Carolco securities.  Because we find that the banks had every               
          economic incentive to exercise their put rights, these preferred            
          distribution rights are irrelevant.                                         
               To the extent that petitioner may be suggesting that                   
          Generale Bank and CLIS continued as partners in SMP because of              
          the contingent payment amount, we disagree.  When Generale Bank             
          and CLIS exercised their put rights at the end of December 1996,            
          they divested themselves of whatever remaining interests they had           
          in SMP.  The contingent payment amount was not a continuing                 
          partnership interest; instead, that amount was part of an open              


               125(...continued)                                                      
          capital accounts the lesser of:  (i) $7 million; and (ii) the “SN           
          Liquidation Value.”  With respect to the Carolco preferred stock,           
          Amendment No. 1 provided that as promptly as practicable after              
          the “PS Liquidation Date”, SMP would distribute to the holders of           
          preferred interests pro rata in accordance with their respective            
          preferred capital accounts the lesser of:  (i) $3 million, and              
          (ii) the “PS Liquidation Value”.                                            





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