- 23 - 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.Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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