Estate of Ross H. Freeman, Deceased, Dennis Hersey, Executor - Page 21

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          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 computer                 




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