- 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 90,000
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