- 31 - substances which could decrease its value. We believe this is quite possible because other parts of the property had been contaminated with pentachlorophenol. Respondent criticizes Goss' conclusion that the highest and best use of the ancillary land was agricultural development and points out that it was zoned for industrial use. We find Goss' opinion that development of the entire site is unlikely because part of it is zoned for farm/forest use to be reasonable. Respondent offered no contrary evidence. Respondent criticizes Goss for failing to consider the potential for planting timber on the ancillary land. However, Goss did just that in discussing the use and zoning of the land. We conclude that the fair market value of the land on March 1, 1988, was $145,000. C. Allocation for Goodwill or Going-Concern Value 1. Section 1060 and the Parties' Contentions The parties agree that section 1060 applies to the Walker asset sale. Under section 1060, assets are divided into four classes: Class I (cash and demand deposits), class II (certificates of deposit, Federal securities, readily marketable stock and securities, and foreign currency), class III (includes accounts receivable, equipment, buildings, land, and covenants not to compete), and class IV (goodwill and going-concern value). Sec. 1.1060-1T(a)(1), (b)(1), (d), Temporary Income Tax Regs., 53Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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