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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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