- 91 -
On its partnership tax return for the taxable year ended
December 31, 1997, SMP reported the sale of the additional 14.65-
percent interest in Corona to Imperial as follows:
$216,750 Sales price
11,864,117 Basis
(11,647,367) Short-term capital loss
This $11,647,367 loss flowed through to the Somerville S Trust
and then through to Mr. Ackerman, who claimed it on his tax
return.
5. Sale of the $79 Million Receivable
On December 29, 1997, Mr. Lerner, on behalf of Corona, and
Mr. van Merkensteijn, on behalf of TroMetro, executed a note
purchase agreement providing for Corona’s sale of the $79 million
receivable to TroMetro. According to this agreement, the
purchase price to be paid by TroMetro was $1,144,000, to consist
of $120,000 cash and a $1,024,000 promissory note payable by
TroMetro to Corona.62
On December 29, 1997, the $120,000 cash amount was paid by
wire transfer. Mr. van Merkensteijn, on behalf of TroMetro,
executed a $1,024,000 promissory note dated December 29, 1997
62 In arriving at a purchase price for the $79 million
receivable, Mr. van Merkensteijn testified that he used the same
pricing formula as in TroMetro’s purchases of the $150 million
and $81 million receivables, and he similarly relied on the Sage
Entertainment appraisal of SMHC’s film assets.
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