- 33 -
if petitioner considered this fact important, petitioner could
have called a witness from Whiteco to testify to the nature of
the negotiations leading up to the sale.
Based on this record, we conclude that the best valuation we
are able to make of the stock of SOAI at January 25, 1982, is on
the basis of the 1981 net sales multiplied by a proper multiplier
and adjusted to the value of the stock by reducing this amount
for liabilities and other necessary items. There apparently is
no dispute between the parties as to the method used by
respondent's expert, Mr. Loe, to determine the value of the stock
from the asset value.
Mr. Ruppert testified, based on a number of sales he
considered comparable to sales of petitioner's assets, that a
proper multiplier for the 1981 sales to arrive at the asset value
at January 25, 1982, was between 2-1/2 and 3. He, therefore,
concluded that a proper multiplier was 2.75. Mr. Ruppert's
records showed very few sales that resulted in multipliers below
2.5 and numerous sales at multipliers of 3 or above. However,
based on the fact that the asset sale made by SOAI in January
1986 showed a multiplier of 2.89 for sign (plant) structures and
an overall multiplier of 3.11, and in the same year of the SOAI
sale a much larger company sold at a multiplier of 3.90, and
approximately a year later a smaller company sold at a multiplier
of 3.38, we conclude that petitioner's sale of assets in January
1986 was at the lower end of the multiplier of sales at that
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