Estate of Joseph Cidulka, Deceased, James S. Bozik, Administrator - Page 29

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          expert used resulted in an amount of approximately $4,470,000 as            
          the worth of the company on January 25, 1982.  Respondent's                 
          expert stated that depreciation should not properly be considered           
          as an operating expense, and that the rent paid by SOAI was paid            
          to members of the Cidulka family and, therefore, was suspect.               
          Respondent's expert concluded that officer's salaries were                  
          overstated and that there were other questionable items deducted            
          as operating expenses by SOAI in 1981.  It is clear that                    
          petitioner's expert and respondent's expert each in effect made a           
          judgment determination as to the operating income of SOAI.  We              
          conclude that from this record an accurate operating income for             
          1981 cannot be determined.                                                  
               Respondent's expert took the position that since many sales            
          of outdoor advertising businesses were negotiated on the basis of           
          a multiplier of gross income or net sales which he concluded in             
          this case were the same, the most appropriate method and best               
          supported method of determining the value of the assets of SOAI             
          would be to apply an appropriate multiplier to the gross income             
          of SOAI for 1981.  The amount of net sales of SOAI as shown on              
          its records for each year here involved is considered to be                 
          accurate by both parties.  After the value of the assets is                 
          obtained by multiplying gross income or net sales by an                     
          appropriate multiplier, certain adjustments are made for                    
          liabilities and certain other items to arrive at the total value            
          of the stock.  Petitioner's experts conceded that there were                




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