- 33 -
Class III Assets
Petitioner's
Purchase
D.C. Walker Agreement Petitioner's Respondent's Respondent's
Enterprises, Inc. and Return Brief Determination Brief
Land $130,000 $145,000 $200,000 $200,000
Buildings and
improvements 120,000 246,000 120,000 120,000
Equipment 850,000 1,000,000 850,000 850,000
Rolling stock 150,000 200,000 150,000 150,000
Lyons Veneer
Buildings
and improvements 75,000 138,608 75,000 75,000
Equipment 250,000 500,000 250,000 250,000
Rolling stock 75,000 90,000 75,000 75,000
Covenants
not to compete
D.C. Walker 1,200,000 1,650,000 750,000 403,000
Mary Walker 150,000 - 0 -
Donna Lee Bebout 150,000 - 0 -
U.S. Forest
Service timber
Sale contracts 1,500,000 1,500,000 1,500,000 1,500,000
Total Class III 4,650,000 5,469,608 3,970,000 3,623,000
Class IV Assets
Goodwill/going-
concern value - 0 - - 0 - 680,000 1,027,000
2. Petitioner's Evidence of the Value of Buildings and
Improvements, Equipment, and Rolling Stock
Petitioner introduced into evidence expert reports with
valuations of buildings and improvements, equipment, and rolling
stock which differ from those contained in the purchase agreement
and petitioner's tax return. Respondent contends that we must
apply the rule in Commissioner v. Danielson, 378 F.2d 771 (3d
Cir. 1967), vacating and remanding 44 T.C. 549 (1965), or
alternatively, the strong proof rule.
Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 NextLast modified: May 25, 2011