Maude G. Furman, Donor, Deceased, and Estate of Maude G. Furman, Deceased, Robert G. Furman, Executor - Page 34

                                       - 34 -                                         
          and $6,574 per share for the Recapitalization.  IPC then                    
          determined that a marketability discount of 35 percent should be            
          applied because of the following factors:  (1) The transactions             
          at issue involved minority interests, which are harder to sell;             
          (2) the size of FIC precluded the possibility of a public                   
          offering; and (3), as of the relevant dates, no dividends had               
          ever been paid by FIC on its common stock.  After applying the              
          marketability discount, IPC determined that the fair market value           
          of the stock, per share, was $7,388 in 1980 and $4,273 in 1981.             
          In comparison, book value per share after applying a 30-percent             
          minority interest discount and a 35-percent marketability                   
          discount was determined to be $4,703 in 1980 and $5,048 in 1981.            
          Applying book value as a floor in the valuation, IPC determined             
          that use of the income method resulted in an undervaluation.                
               Petitioners have relied upon IPC's second method of                    
          valuation, the EBITDA multiple method.  Under this method, a                
          multiple of net earnings before interest, taxes, depreciation,              
          and amortization (EBITDA) was used to determine total enterprise            
          value.  IPC determined the EBITDA of FIC for the FY 1979 through            
          FY 1981.  In valuing the 1980 Gifts, IPC used a multiple of FY              
          1979 EBITDA; a multiple of the weighted average of EBITDA for FY            
          1979 through FY 1981 was used to value the stock transferred in             
          the Recapitalization.  The parties have stipulated FIC's EBITDA             
          for FY 1979 through FY 1981, using the figures determined by IPC.           
               IPC determined that a multiple of 4 to 6 times EBITDA was a            




Page:  Previous  24  25  26  27  28  29  30  31  32  33  34  35  36  37  38  39  40  41  42  43  Next

Last modified: May 25, 2011