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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.
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