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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
brewery.
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.
OPINION
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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