Maude G. Furman, Donor, Deceased, and Estate of Maude G. Furman, Deceased, Robert G. Furman, Executor - Page 25

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          member of the American Society of Appraisers, to which he has               
          never belonged.  Since Mr. Shelton has not demonstrated that he             
          is qualified to perform a business valuation, we will evaluate              
          his opinion accordingly.  See Anderson v. Commissioner, supra at            
          249.                                                                        
               Mr. Shelton used a capitalized earnings method to value the            
          FIC stock at the time of the 1980 Gifts.  Using the capital asset           
          pricing model (CAPM), Mr. Shelton calculated a cost of equity and           
          then computed FIC's weighted average cost of capital (WACC).                
          Earnings before interest, depreciation, and taxes (EBIDT), a                
          variant of EBITDA (earnings before interest, taxes, depreciation,           
          and amortization), were then capitalized using the WACC to arrive           
          at a total enterprise value.  In valuing the 1980 Gifts,                    
          Mr. Shelton projected 12-month earnings from FIC's 10-month                 
          income statement for FY 1979, which he then capitalized to arrive           
          at a February 1980 enterprise value.  Mr. Shelton determined                
          August 1981 enterprise value by capitalizing FY 1980 EBIDT and              
          then adding 5 percent to reflect FIC's value in August 1981.                
               After determining that FIC had a beta of 1.0., Mr. Shelton             
          used the standard CAPM formula to arrive at a cost of equity of             
          18.44 percent.  See description and discussion of beta infra pp.            
          28-30.  Finding that Burger King was the number two fast food               
          chain, Mr. Shelton reasoned that Burger King would be no more or            
          less volatile than the fast food industry as a whole, justifying            
          a beta of 1.0 for FIC's common stock.  In his report, Mr. Shelton           




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