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$43,787 for 1988, $64,689 for 1989, and $74,786 for 1990. After
concessions, we must decide the following issues:
1. Whether the fair market value of three covenants not to
compete on March 1, 1988, is $1,650,000 as petitioner contends,
$403,000 as respondent contends, or some other amount. We hold
that it is $930,000.
2. Whether the fair market value of certain land on
March 1, 1988, is $145,000 as petitioner contends, $200,000 as
respondent contends, or some other amount. We hold that it is
$145,000.
3. Whether the fair market values of buildings and
improvments, equipment, and rolling stock on March 1, 1988, are
$283,000, $1.5 million, and $290,000, respectively, as petitioner
contends; or $195,000, $1.1 million, and $225,000, respectively,
as respondent contends and as petitioner reported on its return.
We hold that they are $384,608 for buildings and improvements,
$1.5 million for equipment, and $290,000 for rolling stock.
4. Whether the fair market value of goodwill on March 1,
1988, is zero as petitioner contends, $750,000 as respondent
contends, or some other amount. We hold that it is zero.
Section references are to the Internal Revenue Code in
effect for the years in issue. Rule references are to the Tax
Court Rules of Practice and Procedure.
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