- 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
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