Maude G. Furman, Donor, Deceased, and Estate of Maude G. Furman, Deceased, Robert G. Furman, Executor - Page 33

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          to compute the August 1981 fair market value of the stock.                  
               IPC applied CAPM principles to determine the rate of return            
          an investor would expect in February 1980 and August 1981.  IPC             
          used market data from Ibbotson Associates13 and determined that             
          the expected rate of return an investor in FIC stock would demand           
          would be equal to the sum of the applicable risk-free rate, risk            
          premium, and small-stock premium, as well as an additional                  
          premium to account for the risk specific to FIC.  To reflect the            
          effect of nominal long-term earnings growth, IPC subtracted a               
          growth factor14 from the expected rate of return and determined a           
          capitalization rate of 21.38 percent for valuing the 1980 Gifts             
          and a 25.50 percent capitalization rate for valuing the stock               
          transferred in the Recapitalization.                                        
               After capitalizing normalized earnings to determine                    
          enterprise value from operations, IPC added the market value of             
          FIC's nonoperating assets to determine total equity value.  IPC             
          computed a per-share equity value of $11,366 for the 1980 Gifts             

               13 The parties stipulated that the Ibbotson Associates                 
          figures used by IPC were correct for the dates in question.  They           
          have not stipulated:  (1) The proper capitalization rate; (2) the           
          correctness of any FIC specific risk premium; or (3) the                    
          correctness of any particular method of computing a                         
          capitalization rate.                                                        
               14 IPC determined growth factors of 8 percent for the 1980             
          Gifts and 7 percent for the Recapitalization, on the basis of the           
          long-term inflation outlook of the Value Line Investment Survey             
          on Feb. 1, 1980, and Aug. 21, 1981.  Apparently, IPC did not take           
          into account the likelihood of real earnings growth attributable            
          to FIC's ability to open more restaurants in its expanding                  
          market, as well as the likelihood of increasing sales in the                
          existing restaurants.                                                       



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