- 38 - If petitioner entered the market and purchased its debt obligations for less than the amount that it had borrowed, petitioner would normally realize income equal to the difference between the amount it borrowed and the amount it paid to purchase its debt instruments. We think that respondent’s argument that petitioner could have received discharge of indebtedness income by repurchasing its debt at a discount supports our conclusion that petitioner’s favorable financing had value. C. Respondent’s Argument That the Value of Petitioner’s Favorable Financing Is Limited to the Value of Petitioner’s Income Spread Assuming, without conceding, that favorable financing is a valuable asset, respondent argues that the price an acquirer would pay to purchase petitioner’s rights and obligations with respect to its CMOs or GMCs would not exceed the present value of petitioner’s spread income associated with those instruments. As of January 1, 1985, respondent asserts that the present value of the spread related to petitioner’s GMCs and CMOs equaled approximately $11.4 million and $7.2 million, respectively. Dr. Hakala concluded that favorable financing is not an intangible asset; however, Dr. Hakala found that petitioner’s income spread has value because its assets and liabilities are closely matched.15 According to Dr. Hakala, when previously 15 Dr. Hakala indicates that the CMOs and GMCs are exactly matched.Page: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Next
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