Santa Monica Pictures, LLC, Perry Lerner, Tax Matters Partner - Page 172

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          possibly in excess of $200 million; however, any use of the NOLs            
          would be severely limited by MGM Group Holdings’ absence of                 
          income and the interest owed on its debts, as well as the NOL               
          limitations under section 382.  These assets provided no                    
          meaningful basis for repaying the $79 million receivable, even              
          under the best of estimates.  Despite these infirmities, Credit             
          Lyonnais released New MGM from its $79 million debt obligation              
          and caused MGM Group Holdings to assume this amount.                        
               MGM Group Holdings had a long track record of failing to               
          repay the loans and advances that the Credit Lyonnais group had             
          made to it.  Following the 1993 restructuring, MGM Group Holdings           
          retained approximately $962 million in debt that the MGM                    
          companies owed to the Credit Lyonnais group.  After additional              
          advances in 1994 and 1995, MGM Group Holdings owed approximately            
          $975 million in indebtedness to CLBN, including some capitalized            
          interest.  This amount remained owing as of October 10, 1996.               
          MGM Group Holdings paid no principal amount of this indebtedness;           
          there is no evidence that it was ever called upon to make any               
          repayment.                                                                  
               For many years, MGM Group Holdings paid no interest on its             
          debt obligations to the Credit Lyonnais group.  In connection               
          with the 1993 financial restructuring of MGM, MGM Group Holdings            
          and CLBN agreed that $800 million of MGM Group Holdings’ debt               
          obligations would be noninterest bearing.  MGM Group Holdings               






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