Pabst Brewing Company - Page 2

                                        - 2 -                                         
               each asset is the corresponding amount set forth in the                
               allocation agreement.                                                  

               William M. Bitting, William A. White, and Dean E. Dennis,              
          for petitioner.                                                             
               Alan M. Jacobson and Steve R. Guest, for respondent.                   


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               LARO, Judge:  Pabst Brewing Co. petitioned the Court to                
          redetermine respondent's determination of the following                     
          deficiencies in its Federal income taxes and additions thereto              
          under section 6661:                                                         
                                                         Additions to Tax            
               Year or period ended     Deficiency         Sec. 6661                  
                    12/31/81            $58,241             ---                       
                    3/18/83        28,188,661          $4,167,682                     
                    3/19/831            28,188,661          4,167,682                 
                    12/31/83             2,483,904     620,976                        
                    12/31/84       2,953,841           ---                            
                    2/28/85        234,115             58,529                         
               1Petitioner had two taxable periods during the 1983 calendar           
          year, the first period ended in mid-March and the second period             
          ended Dec. 31.  Petitioner filed its return using Mar. 18, 1983,            
          as the ending date of the mid-March period.  Respondent                     
          determined that the proper ending date was Mar. 19, 1983, but               
          alternatively determined that the taxable period ended Mar. 18,             
          1983.  The parties agree that the mid-March period ended                    
          Mar. 19, 1983.                                                              
          Following the resolution of all other issues in this case, we               
          must decide the fair market value of certain assets (Transferred            
          Assets) that petitioner transferred to G. Heileman Brewing Co.              
          (Heileman) during the taxable period ended March 19, 1983.                  




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011