Potential Earnings and Synergies Relevant in Determining Fair Market Value of Transferred Subsidiary

Business Valuation Update BVLaw
Legal and Court Case Update
November 15, 1999
3429 Hardware, NEC
332510 Hardware Manufacturing
federal taxation

BTR Dunlop Holdings, et al. v. Commissioner
T.C. Memo 1999-377, 1999 Tax Ct. Memo LEXIS 432
Federal Court
United States Tax Court
Lawrence Gooch(for taxpayer)<br>Kenneth Button(for taxpayer)<br>Wilfried Lahmann(for taxpayer)|Herbert Spiro (for taxpayer)|Alan Shapiro (for IRS)


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 ...