- 48 - We find no support in the record for respondent’s allegations of unduly pessimistic valuation in connection with the discontinued operations writedowns. Petitioner presented the expert testimony of Justin A. Gannon, an audit partner in the San Antonio office of Arthur Andersen LLP, on the propriety of adopting discontinued operations treatment with respect to G�nther for FYE May 31, 1992. Respondent stipulated that Mr. Gannon was an expert in the field of accounting. Mr. Gannon’s report sets forth the underlying facts in support of his conclusion that discontinued operations treatment was appropriate. Respondent did not offer any expert testimony to rebut Mr. Gannon’s testimony. Our consideration of all the evidence in this case, including but not limited to Mr. Gannon’s testimony, convinces us that petitioner’s decision to adopt discontinued operations treatment was consistent with U.S. GAAP and appropriate under the circumstances herein.31 Moreover, petitioner has convinced us that its efforts with respect to G�nther were directed to minimizing the substantial economic losses it reasonably anticipated from G�nther’s catastrophic financial implosion and were not structured to distort its tax position. 31We note that the value of G�nther’s interest in Actium was increased as a result of discontinued operations treatment. This writeup belies respondent's claim that discontinued operations treatment was undertaken solely to buttress petitioner's claim that G�nther had become worthless.Page: Previous 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 Next
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