- 26 - CMO A-2 99.4511 97.664063 350,000,000 CMO A-3 99.2668 96.390625 435,000,000 CMO C-4 95.6239 94.890625 85,052,100 1 The adjusted issue price is the unpaid principal balance minus the fraction of any unamortized original issue discount remaining as of the valuation date. For a debt instrument issued at a price that equaled its face value and for which there had been no redemption before Dec. 31, 1984, the adjusted issue price equals the initial face amount. The adjusted issue price listed above is the adjusted issue price per $100 of unpaid principal balance. 2 The Jan. 1, 1985, market price equals the middle price-- this is the average of the bid and asked prices. With the exception of G-15 and G-16, Professor Schaefer used the average of the bid prices obtained by Arthur Andersen and petitioner from the Salomon Brothers, First Boston, Merrill Lynch, and Shearson Lehman investment banks as the bid price. See appendix. The bid prices for G-15 and G-16 equaled the average of the available prices. We find that petitioner’s method of valuing its favorable financing intangible assets provides a reasonable estimate of fair market value. The Supreme Court in Dickman v. Commissioner, 465 U.S. 330, 337-338 (1984), indicated that the value of the right to use borrowed money is readily measurable by reference to current interest rates. See also Rev. Proc. 85-46, sec. 3.01, 1985-2 C.B. 507 (stating that the value of a gift below-market loan is “the difference between the rate at which the money is loaned and the prevailing market rate.”). Similarly, we believe that the favorable financing aspect of petitioner’s debt instruments may be valued by comparing petitioner’s effective contract interest rates to the prevailing market rates for thosePage: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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