- 26 - of an expert's testimony and reject others. Helvering v. National Grocery Co., 304 U.S. 282 (1938). Petitioners' expert, Mr. Robert Conklin of Ernst & Young, relied solely on the income approach in valuing the SWI stock. Mr. Conklin did not use the market comparison approach because he believed that there were no sufficiently comparable companies in existence as of the valuation date. He did not use the cost approach because he felt it "tends to minimize the value of assets and fails to consider intangibles such as goodwill." Mr. Conklin utilized a "discounted cash flow analysis" to calculate the fair market value of SWI stock. Under this analysis, the value of stock is equal to the present value of the cash flow the company is expected to generate in the future. Mr. Conklin began his analysis by estimating SWI's net income for the 10- year period from 1990 to 1999, and what he described as a "terminal year". He calculated this net income figure by estimating the total sales SWI could expect to generate from each store and multiplying by the number of stores SWI could be expected to operate each year. Mr. Conklin assumed that SWI would expand its operations rapidly from 1989 to 1994, and that it would open a constant number of new stores each year thereafter until 1999, reaching a total of 271 stores in that year. He also assumed thatPage: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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