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Technology Stocks : Leap Wireless International (LWIN)

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To: Jon Koplik who wrote (49)9/24/1998 10:55:00 AM
From: Robert J. Irvin  Read Replies (1) of 2737
 
If you are also an owner of Quallcom shares, you should not want Leap's stock to trade higher today. Page 36 of Leap's September 14 Information Statement states that "the fair market value of the Leap shares...will constitute a dividend taxable as ordinary income" and that "the fair market value of a Leap Share to a Holder for this purpose is expected to be the average of the high and low trading price on the date of the Distribution", which is today. Note, not the closing price today.

Example: if the average of the high and low trading price today is $5, then an owner of 1,000 QCOM shares has a taxable dividend of $1,250, which cannot be offset against capital losses. If Leap's price then increases to $10, he has a $5 gain which can be offset against capital losses, for no current tax.

At these prices, the discussion of Quallcom's accumulated "earnings and profits" for federal income tax purposes probably doesn't make any difference, since the total value of the Leap distribution at $5 would be under $100 million.

I hope your investment does well, starting tomorrow. Good luck.
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