Phillip M. Welch and Dorothy Ellen Welch - Page 24

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             client turnover factor does not overlap the effect of                     
             death, retirement, and relocation.                                        
                  Respondent introduced the expert report and testimony                
             of Mr. Paul Meade.  In summary, Mr. Meade concluded that                  
             the amount paid by petitioner for the seller's accounting                 
             practice should be allocated as follows:                                  
                       Going concern             $16,000                               
                       Goodwill                  --                                    
                       Client list               145,225                               
                       Non-compete covenant       --                                   
                      Total                     161,225                               

             As depicted above, Mr. Meade concluded that approximately                 
             10 percent of the amount paid by petitioner, $16,000, must                
             be allocated to going-concern value and the remainder,                    
             $145,225, must be allocated to the client list.  Mr. Meade                
             also concluded that the useful life of the client list in                 
             petitioner's accounting business is at least 15 years.                    
                 Mr. Meade used an income analysis in order to compute                
             the useful life of the subject client list in petitioner's                
             business.  Based upon published industry figures, he                      
             concluded that a business like the seller's accounting                    
             business would realize "operating income" before the                      
             owner's salary in the amount of 40 percent of gross                       
             receipts.  In view of the fact that the subject agreement                 
             calls for petitioner to pay 25 percent of the gross                       
             receipts to the seller for 48 months, Mr. Meade concluded                 




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