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however, none of these transactions actually resulted in a
transaction between SMP, SMHC, and the other companies. Further,
although petitioner submitted various exhibits indicating his
contacts with the various parties, we have no basis from which to
evaluate the content or the scope of the alleged discussions and
negotiations. At best, the Ackerman group’s various attempts to
engage in film activities through SMP might be relevant in
determining whether SMP was a bona fide partnership for Federal
tax purposes; however, respondent does not dispute that SMP is a
bona fide partnership. These film-related activities are
unrelated to the CDR transaction and do not persuade us that the
banks intended to enter a film distribution business with the
Ackerman group, as petitioner claims.
163(...continued)
regarding the distribution of SMHC’s films in connection with its
cable business; (6) a possible acquisition of the Crossroads film
library in 1997; (7) negotiations with Atlas Entertainment in
1997 and 1998 regarding the development of a production capacity
inside of SMHC; (8) a business proposal to establish an African-
American film distribution company with C. O’Neill Brown in 1998;
(9) a possible transaction with Reisher Entertainment in 1998;
(10) a possible acquisition of the feature film library of the
Modern Times Group in 1998; (11) negotiations with Frank Klein,
who was president of PEC Israeli Economic Corp. in 1998; (12)
negotiations regarding the sale of Polygram Filmed Entertainment
in 1998; (13) a possible merger of SMHC with, or acquisition by,
Artisan Entertainment in 1998; (14) a possible business venture
with Regent Entertainment, Inc. in 1998; (15) negotiations for
the purchase of film titles from Silver Screen International and
Aries Entertainment, Inc., in 1999; and (16) a possible film deal
involving Broadcast.com. in 1999. Petitioner also points to
discussions with Alan Cole Ford, formerly of MGM, regarding his
acquisition of Paul Kagan Associates.
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