Summary
The issue in this corporate income tax matter is the fair market value, for purposes of IRC §§ 311(b) and 482, of Schlegel UK Holdings Ltd. and Schlegel GmbH, which were transferred from the taxpayer, BTR Dunlop Holding, Inc., to the taxpayer's parent corporation, BTR, Plc.
See Also
BTR Dunlop Holdings, et al. v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...