- 32 - Fed. Reg. 27039-27040 (July 18, 1988). The total consideration is allocated to class I assets in an amount equal to each asset's face value. The remaining consideration is then allocated to class II assets in proportion to the fair market value of each class II asset. The remaining consideration is then allocated to class III assets in an amount equal to the fair market value of each class III asset. Any residue is allocated to class IV. Sec. 1.1060-1T(d), Temporary Income Tax Regs., supra. Petitioner argues that no value should be allocated to class IV because the value of class III assets exceeds the sale price. Respondent determined that the sale price exceeded the value of the class III assets by $680,000 on March 1, 1988. Respondent contends that the sale price exceeded the value of class III assets by $1,027,000. The parties agree that the value of the timber contracts was $1.5 million on March 1, 1988. We have decided that the values of the land and covenants not to compete were $145,000 and $930,000, respectively. Petitioner contends that the fair market values of building and improvements, equipment, and rolling stock were as provided in the reports of its expert witnesses. The following chart shows the parties' positions relating to the allocation for all assets:Page: 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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