Leo J. Polack - Page 15




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          to the MLOCR or any expenses related to any other portion of the            
          presorting division would be capital in nature, this                        
          misunderstanding does not persuade us that ZSI would incur                  
          capital expenditures with regard to the presorting division.                
               Likewise, petitioner’s arguments that respondent’s                     
          projections of capital expenditures are inconsistent with ZSI’s             
          history of expenses, projected level of growth, and projected               
          depreciation are not supported by evidence.  Specifically,                  
          petitioner alleged that respondent’s projections (1) improperly             
          reduce ZSI’s assets’ book values during a period of corporate               
          growth; (2) improperly depreciate assets not yet acquired; and              
          (3) fail to recognize that proper appraisal methodology would               
          project a growing company’s capital expenditures to be relatively           
          equal to its depreciation, in order to maintain the asset base.             
          As discussed below, we disagree with petitioner.                            
               Petitioner has not directed us to any authority that a                 
          decline in a corporation’s assets’ book values is irreconcilable            
          with that corporation’s growth.  ZSI’s growth is tied more                  
          closely to the service fees, the presorting discounts, and the              
          value-added refunds it generates than to its assets’ book                   
          values.13  We therefore are not persuaded by petitioner’s                   


               13For 1993 and 1994, it appears that respondent projected              
          ZSI’s assets’ cumulative book value to increase, as ZSI’s capital           
          expenditures are projected to exceed its depreciation allowances.           






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