Lorvic Holdings, Inc. - Page 25

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            agreements by determining petitioner's value without the                                    
            agreements and subtracted that value from the previously                                    
            determined value of the business with the agreements.  The                                  
            difference in value of the business was held to be directly                                 
            attributable to the agreements.                                                             
                  Dr. Schutte valued petitioner's business without the                                  
            agreements to be $4,924,636.  In that vein, he calculated that,                             
            in the aggregate, prior to the consideration of the actual                                  
            transaction value, the agreements were worth $3,330,413.  Then,                             
            he divided $3,330,413 by $8,255,049 to reach a figure of 0.4034.                            
            In other words, Dr. Schutte believed that the value of the                                  
            agreements was equivalent to 40.34 percent of the purchase price                            
            of $8.14 million.                                                                           
                  Second, petitioner presented Thomas P. Lee (Lee) an                                   
            appraiser of business and intangible assets for Arthur Andersen,                            
            L.L.P.  Lee possesses an M.B.A. from New York University.  He                               
            also has an M.S. as well as a B.S. in civil engineering from the                            
            Polytechnic Institute of New York.  Lee is a member of, and has                             
            attended conferences and seminars with, the American Society of                             
            Appraisers.   Prior to his tenure with Arthur Andersen, L.L.P.,                             
            Lee was employed by several accounting and valuation firms                                  
            including, among others, Ernst & Young, L.L.P.  Subsequent to the                           
            1989 transaction, while employed with Ernst & Young, L.L.P., Lee                            







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