category of assets making up the Washington properties was as follows: Timber & timberland $31.0 million Development property 10.5 million Port Ludlow community 4.5 million Port Gamble townsite 2.5 million and tree nurseries $48.5 million The $1.5 million in cash transferred to the Partnership was not included in the assets that we valued. Furthermore, we did not consider, nor did we intend to include, any portion of the working capital in determining the fair market value of the Washington properties. Respondent's Rule 155 computation correctly treats the $1.5 million of working capital as being separate from the Washington properties that we valued in Pope & Talbot II. Allocation of Expenses In Pope & Talbot II, we found that petitioner incurred $1,364,071 in expenses relating to the formation of the Partnership, the transfer of the Washington properties, and the distribution of the partnership units. The overall purpose of these activities was to distribute the Washington properties. We held that petitioner may offset its expenses incurred in connection with the distribution against its section 311(d) gain. We did not find that these expenses related to either the transfer of the cash or the separate sale of the installmentPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011