-55- acquire land and construct a plant; and (3) petitioner was committed to retain the PCC investment for 12 years, while no similar mandatory holding period existed in G.M. Trading. Moreover, petitioner contends that unlike G.M. Trading, the step transaction doctrine applies herein; thus, the exchange of debt for cruzados and the cruzados conversion into stock should be ignored. Therefore, according to petitioner, the gain or loss should be measured by the difference between the basis in the debt and the fair market value of the stock received. In order to place a value on the stock, petitioner submitted the expert report of Nancy Czaplinski, who valued petitioner's interest in the PCC stock as of the transaction date at $5,544,000. Petitioner also submitted the expert report and testimony of Steven J. Sherman, who valued the same interest at approximately $6.77 million.33 Finally, petitioner claims that the value of its blocked deposits on the secondary market is directly relevant to the value of its equity interest in PCC. According to petitioner, the $12,577,136 of blocked deposits had a $7,923,596 value on the 33 Respondent's appraisal experts, Scott Hakala and William Cline, valued the interest at $12 million and $12.5 million, respectively.Page: Previous 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 Next
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