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date, the multiplier used for the 1986 sale gives an indication
of how the value of all the SOAI assets might be determined for a
sale at fair market value at an earlier date. This is
particularly true where, as here, some asset sales of other
companies are shown to have been made near the January 25, 1982,
valuation date at a multiplier of around the multiplier at which
SOAI's assets were sold in 1986. The record also contains one
sale within a year of the SOAI asset sale at a multiplier
slightly greater than the multiplier determined for the SOAI
sale. Therefore, in our view, the sale by SOAI in January 1986
of all its assets has relevance in determining an appropriate
multiplier to determine the fair market value of SOAI's assets on
January 25, 1982.
Petitioner attacked the data used by respondent's expert to
obtain the net sales multipliers by referring to a book written
by a recognized appraiser with respect to net sale multipliers.
However, even if such an out-of-court statement could have value
in any case, the statement referred to by petitioner does not,
since it is unclear to which companies it would apply.
Respondent's witness, Mr. Ruppert, kept his database for use in
advising business clients with respect to purchases and sales of
the assets of outdoor advertising companies. In our view, Mr.
Ruppert's database is reasonably accurate and supports his
opinion.
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