Flint Industries, Inc. and Subsidiaries - Page 15




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          assess the period of time operations will continue until disposal           
          and the expected results of operations over that time period.               
          U.S. GAAP also requires management to evaluate the expected                 
          outcome from the disposal of the business unit.  In order to do             
          so, management is required to adjust the value of the unit’s                
          assets from book value to net realizable value.13                           
               After conducting a review of G�nther’s assets and obtaining            
          appraisals where necessary, petitioner’s management concluded:              
          (1) The values of most of G�nther’s book assets must be adjusted            
          downward to reflect that their net realizable values were lower             
          than their book values; (2) the value of G�nther's ownership                
          interest in Actium must be adjusted upward to reflect its net               
          realizable value in excess of book value; and (3) G�nther’s                 
          liabilities substantially exceeded the fair market value of                 
          G�nther’s assets as of May 31, 1992.                                        
               On its consolidated statement of operations and retained               
          earnings for FYE May 31, 1992, petitioner reported a loss from              


               13For Federal estate, gift, and income tax purposes, fair              
          market value means “the price at which the property would change            
          hands between a willing buyer and a willing seller, neither being           
          under any compulsion to buy or to sell and both having reasonable           
          knowledge of relevant facts.”  United States v. Cartwright, 411             
          U.S. 546, 551 (1973); Martin Ice Cream Co. v. Commissioner, 110             
          T.C. 189, 220 (1998).  Although net realizable value is an                  
          accounting concept which apparently refers to the net value                 
          realizable from the sale or disposition of a business unit and/or           
          its assets and is not necessarily the same as fair market value,            
          we are satisfied that petitioner’s management calculated the fair           
          market value of G�nther’s assets and that those values were                 
          considered in determining the net realizable value of G�nther’s             
          assets for financial statement purposes.                                    




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