- 10 -
building products divisions of Schlegel UK and provided them to
VRC along with expense forecasts and historical financial data.
From this information, VRC prepared a document entitled "Schlegel
UK Projections" that projected continued profit growth for
Schlegel UK.
VRC opined in a letter dated April 28, 1989, that the fair
market value of Schlegel UK was $32,363,000 with a bargain
purchase value of $21,846,000 and, in a separate letter dated
April 28, 1989, indicated that the value of Schlegel GmbH was
$3,777,000, exclusive of the silent partnership interest. After
discovering certain clerical errors, VRC mailed a letter on
September 15, 1989, that confirmed that the correct bargain
purchase value of Schlegel UK was $21,846,000.
Accordingly, pursuant to a stock purchase agreement dated
July 1, 1989, Schlegel Holding Company sold all of the stock of
Schlegel UK to BTR Plc for $21,846,000. As of the date of sale,
the Schlegel Holding Company’s adjusted basis in Schlegel UK was
$2,310,863. On November 30, 1989, Schlegel Corporation sold
99.9 percent of Schlegel GmbH to BTR International, .1 percent of
Schlegel GmbH to BTR Secretaries, and its interest in the silent
partnership to BTR International. Schlegel Corporation received
$9,400,000 in consideration for this transaction. The adjusted
tax basis, book value, and fair market value of the Schlegel
Corporation’s interest in the silent partnership was $5,116,136.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011