- 31 - Total--Transferred Assets 190,287,375 --- --- --- 130,000,000 We do not accept the conclusions of any of the experts in toto, but we find parts of each of their opinions to be helpful in understanding the operation of the beer industry.12 With respect to Tonna, we find his testimony on the valuation issue to be unpersuasive. Although he valued the subject breweries by reference to the sales of other breweries which he believed to be comparable, the dates of many of the purportedly comparable sales were too far removed from the valuation date at hand to allow for a meaningful comparison. Wolfsen Land & Cattle Co. v. Commissioner, 72 T.C. 1, 19-20 (1979). Moreover, Tonna's report does not set forth enough data on these other breweries to allow the Court to make a meaningful comparison. Although his report states the barrel capacity of his comparable breweries as well as certain other information with respect thereto, we do not know, for example, the quality, quantity, or attributes of the machinery and equipment, the size of the building, or the amount of land that were included in each purportedly comparable sale. We also do not know the particularities of any other asset that may have been included in each sale. A proffered comparable sale without enough identifying data to explain the components of the sale is usually unhelpful to the Court in valuing property. 12 In this regard, we will deny a motion made by petitioner at trial (and taken by the Court under advisement) to strike Weinberg's testimony.Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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