- 21 - sum the present value of cash-flows expected after year 5 (the reversion). We agree with respondent’s corrected computation of the present value of the reversion. Also, we are satisfied with his use of the market approach. Indeed, three of the companies selected by Spiro as comparable were selected by Klemm in his initial report, which accompanied the estate tax return. We agree with Spiro’s application of a liquidity discount of 10 percent. We also agree with the weight he gave the results reached under the two approaches. B. Petitioner’s Criticism Petitioner has criticized Spiro’s testimony on numerous grounds. Implicitly, we have dealt with most of that criticism in our analysis of Spiro’s report. We have not, however, dealt with petitioner’s claim that Spiro failed to recognize the effect on the value of the shares of the June 9, 1986, technology sharing agreement (agreement) entered into with Monolithic Memories, Inc. (MMI). The agreement was terminated in 1990. The agreement, argues petitioner, decreased the corporation’s earnings potential (and therefore decreased the value of the corporation) because MMI (and later its successor, AMD) could produce and sell, at lower prices, products using the corporation’s technology. We do not think that Spiro failed to take the agreement into account. The pace of change for technology in the computerPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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