properties; respondent disagrees;2 and (2) respondent maintains that a portion of the $1,364,071 in expenses should be allocated to the transfer of $1.5 million in working capital and to the sale of the installment notes receivable; petitioner disagrees. Inclusion of Working Capital In Pope & Talbot II, the primary issue for decision was the fair market value of the Washington properties distributed by petitioner. Our valuation was limited to the fair market value of timber, timberland, land development and resort properties, and related assets on the Washington properties. Neither the value of the $1.5 million in cash transferred to the Partnership nor the value of the installment notes receivable sold to the Partnership was in dispute in Pope & Talbot II. In determining the fair market value of the Washington properties, we grouped the properties into four separate categories and described the assets in each category. These descriptions include, for example, the amount of merchantable timber that could be harvested, the amount of land that could be developed, and the various improvements on the properties. We examined the assets in each category and, with the assistance of expert valuation reports, determined the fair market value of assets in each category. We concluded that the value of each 2Petitioner's Rule 155 computation treats the working capital as part of the Washington properties, in effect, reducing the fair market value of the Washington properties by $1.5 million.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011