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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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