- 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.
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