-69-
1996-395. While we find Dr. Cline's analysis generally sound,
based on all of the evidence before us, we believe, and
accordingly hold, that the 12-year repatriation restriction
warrants a 15-percent discount, rendering a $1,886,570 loss for
petitioner's 1987 tax year.
Issue III. Allocation of Purchase Price
The final issue concerns the value of a lease portfolio
petitioner acquired from Financial Investment Associates, Inc.
(FIA). In this regard, we must determine whether any portion of
the $141,456,620 petitioner paid in 1989 to acquire the assets of
FIA should be attributed to goodwill, going-concern value, or
other nonamortizable intangible assets. Petitioner contends that
none of the $141,456,620 it paid for FIA's assets should be
allocated to goodwill, going-concern value, or other
nonamortizable intangible assets. Respondent, on the other hand,
contends that $1,328,618 of the $141,456,620 should be allocated
to nonamortizable intangible assets.
A. FIA
FIA, a medical equipment leasing company, was founded by Fred
Rafanello in 1977. At FIA's incorporation, Mr. Rafanello was its
sole owner, president, and chief executive officer (CEO). FIA's
principal executive offices were located in Northfield, Illinois.
Page: Previous 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 NextLast modified: May 25, 2011