- 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 thatPage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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