Pabst Brewing Company - Page 31

                                       - 31 -                                         
          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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