- 37 - 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 90,000Page: 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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