- 46 -
price already reflects taxes. Mr. Scribner confirmed that the
market price incorporates the effect of taxes. We find that
petitioner properly valued its favorable financing intangible
assets using the market-based method and that no further
adjustment is necessary to account for the tax effect.
We agree that petitioner has proven that its favorable
financing intangible assets have values that were reasonably
estimated. We hold that the values of petitioner’s favorable
financing intangible assets are as follows:
Debt Fair market value
G-15 $8,865,451
G-16 14,986,068
G-17 44,427,083
F-8 325,000
F-11 92,000,000
F-12 187,500
F-13 72,937,500
F-15 218,750
F-18 125,000
D-2 5,812,500
Z-2 24,389,887
Z-3 1,448,674
ND 458,071
CD-1 7,992,188
GMC A 1975 7,418,813
GMC B 1975 4,358,750
GMC A 1976 5,228,813
GMC B 1976 8,342,336
GMC A 1977 8,146,021
GMC B 1977 12,825,330
GMC C 1977 17,407,946
GMC A 1978 24,814,023
GMC B 1978 12,413,781
GMC C 1978 9,776,662
GMC A 1979 8,521,734
GMC B 1979 6,626,888
GMC C 1979 8,946,893
CMO A-2 6,254,753
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