Freres Lumber Co., Inc. - Page 2

                                                  - 2 -                                                    

            $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.                                                         







Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011