Norwest Corporation and Subsidiaries - Page 48

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         The cruzado proceeds would remain subject to the same prohibition            
         on repatriation, until April 14, 1999.                                       
              F. Petitioner's Tax and Accounting Treatment of the Conversion          
              NBM's chief financial officer and comptroller, Phil Williams,           
         reviewed and analyzed the Corporate Finance study. Two days after            
         the conversion he concluded that the estimated fair market value of          
         petitioner's 14.361-percent equity interest in PCC was between               
         $12.4 million and $12.6 million.  Mr. Williams arrived at this               
         conclusion by using the price/equity ratio and discounted cash-flow          
         approaches, as well as adding a third approach, based on the net             
         book value of PCC.  He then weighted the three approaches equally.31         
         Mr. Williams recommended that the investment be recorded at par.             
         In April 1987, Mr. Narayana (who was in charge of petitioner's               
         Brazilian blocked deposits) agreed with Mr. Williams' conclusion.            



               31   Mr. Williams determined the fair market value of                  
          petitioner's interest in PCC as follows (numbers are in                     
          thousands):                                                                 
                                                                                     
          Method                Total Company        Norwest's Share                  
          Price/earnings ratio     $ 79,385  x  14.361% =     $11,400                 
          Discounted cash-flow       79,790  x  14.361% =      11,459                 
          Net book value            1100,386  x  14.361% =      14,416                
          Weighted average         $ 86,520                   $12,425                 
               1 Discounted 20 percent.                                               






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