Freres Lumber Co., Inc. - Page 37

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            without an expert appraisal.  Cf. Mooneyham v. Commissioner, T.C.                              
            Memo. 1991-178.  The record does not show how the Freres family                                
            chose the amounts they used in the agreement.  We believe                                      
            Gwyther's and Goss' opinions of value are entitled to                                          
            considerably more weight than the opinions of the members of the                               
            Freres family.  We conclude that petitioner is entitled to                                     
            prevail on the allocations for buildings and improvements,                                     
            equipment, and rolling stock, even if a strong proof standard                                  
            applies.                                                                                       
                  We conclude that the proper allocations of value under                                   
            section 1060 for the class III assets are $384,608 for buildings                               
            and improvements, $1.5 million for equipment, and $290,000 for                                 
            rolling stock.                                                                                 
                  3.     Calculation of Goodwill and Going-Concern Value Under                             
                         Section 1060                                                                      
                  Petitioner paid $4.65 million for the Walker assets.  To                                 
            allocate the purchase price to assets under section 1060, we                                   
            subtract from that amount the following values for class III                                   
            assets:                                                                                        
            D.C. Walker Enterprises, Inc.                                                                  
            Land                          $145,000                                                         
            Buildings and improvements      246,000                                                        
            Equipment                    1,000,000                                                         
            Rolling stock                  200,000                                                         
            Lyons Veneer                                                                                   
            Buildings and improvements     138,608                                                         
            Equipment                      500,000                                                         
            Rolling stock                   90,000                                                         





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