Estate of Joseph Cidulka, Deceased, James S. Bozik, Administrator - Page 33

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          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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