Pabst Brewing Company - Page 23

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          reported a net gain of $23,840,818 resulting from the transfer of           
          the remainder of the assets to Heileman on the former date.                 
               Respondent, as reflected in her notice of deficiency,                  
          determined that the fair market value of the Perry and Portland             
          breweries and the brands of beer exceeded the values reported by            
          petitioner.  On June 6, 1996, petitioner amended its petition to            
          raise the issue of the fair market value of the San Antonio                 
               In 1983, there was a market for brewing assets, and there              
          were brewers that could have purchased and utilized the relevant            
          breweries, as well as the brands of beer.                                   
               Following a 3-day trial, we must decide the fair market                
          values of the Transferred Assets.  The parties have agreed that             
          the values of certain assets equal the amounts set forth in the             
          Allocation Agreement, leaving the Court to decide the values of             
          the Perry, Portland, and San Antonio breweries, as well as the              
          brands of beer.  The record is replete with charts, graphs, data,           
          testimony, and expert opinion.  We must evaluate all of the                 
          evidence and render a judgment.  As the Court has observed, the             
          valuation of property is an inexact science, and, if not settled            
          by the parties, must be resolved by the judiciary by way of                 
          "Solomon-like" pronouncements.  Buffalo Tool & Die Manufacturing            
          Co. v. Commissioner, 74 T.C. 441, 452 (1980); Messing v.                    
          Commissioner, 48 T.C. 502, 512 (1967); see also Mandelbaum v.               

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