- 92 - (the $1,024,000 TroMetro note).63 On December 10, 1998, TroMetro paid $205,191 principal and $82,600 interest on the $1,024,000 TroMetro note. No other cash payments were made on the $1,024,000 Trometro note. On its partnership tax return for the period December 16 to 31, 1997, Corona reported a $78,768,955 long-term capital loss on the sale of the $79 million receivable. In computing this loss, Corona reported a $1,144,000 sale price and $79,912,955 basis for the $79 million receivable. The loss flowed through to Imperial in the amount of $74,671,378 and to SMP in the amount of $4,097,577. SMP’s $4,097,577 loss then flowed through to Somerville S Trust and finally through to Mr. Ackerman. On Schedules K-1 attached to its return, Corona reported the sale of the $79 million receivable as a $74,671,378 decrease in Imperial’s capital account and a $4,097,577 decrease in SMP’s capital account. 6. Imperial’s Capital Contribution On January 15, 1998, Corona’s members executed a second amendment to the amended and restated Corona LLC agreement, providing that “At the end of any year in which there are 63 At some point, Mr. van Merkensteijn, on behalf of TroMetro, executed a second promissory note also dated Dec. 29, 1997, in the amount of $1.180 million (the $1.180 million TroMetro note). Mr. van Merkensteijn testified that the first note was corrected to reflect a different amount. The $1,024,000 TroMetro note in the record has the handwritten notation “Cancelled” on its first and last pages.Page: Previous 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 Next
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