BTR Dunlop Holdings, Inc. - Page 2




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               (1) What was the value of Schlegel U.K. Holdings, Ltd.                 
          (Schlegel UK), and Schlegel GmbH on July 1, 1989, and                       
          November 30, 1989, respectively, for purposes of section 311(b)             
          and section 482 and                                                         
               (2) what was the Schlegel Corporation’s adjusted tax basis             
          in Schlegel GmbH on November 30, 1989.                                      
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the year in issue, and              
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the facts set              
          forth in the stipulation are incorporated in our findings by this           
          reference.                                                                  
          Schlegel Corporation                                                        
               Schlegel Corporation is a New York corporation that was                
          formed on August 10, 1900.  Its primary businesses were the                 
          production of automotive, building, and industrial seals, and its           
          subsidiaries included Schlegel UK and Schlegel GmbH.  During the            
          relevant period, Schlegel Corporation had manufacturing                     
          facilities in 12 countries; design centers in Bardon Hill,                  
          England, and Detroit, Michigan; and technical centers in Bardon             
          Hill, England, and Rockford, Tennessee.  The technical centers              







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