- 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.Page: Previous 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 Next
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