Norwest Corporation and Subsidiaries - Page 55

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         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.                                                      






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