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discounted cash-flow analysis to determine the present value of
one or more future cash-flows. See, e.g., Plumb v. Commissioner,
7 B.T.A. 295, 297 (1927); Willamette Indus., Inc. v.
Commissioner, T.C. Memo. 1990-339 (setting forth the algebraic
formula to determine the present value of a future payment).
When properly applied, a discounted cash-flow analysis is a
reliable tool for financial analysis. The difference in opinions
as to value reached by the two expert witnesses, at least to the
extent it is attributable to the discounted cash-flow approach,
is exclusively the result of differences between them as to the
values of certain variables, not a difference as to methodology.
Therefore, since we find the discounted cash-flow analysis to be
a reliable tool to determine the present value of one or more
future cash-flows, we believe that petitioners’ argument, to wit,
that Dr. Bajaj’s opinion is based on unreliable methodologies, is
nonsensical.
Because we find that both parties' experts relied on the
same acceptable valuation methodology, and that the areas of
disagreement between the experts are merely factual disagreements
over various factors and assumptions, we need not address further
petitioners' second concern, that Dr. Bajaj's "method" has not
been subjected to peer review.
Finally, we address petitioners' last contention, that the
data Dr. Bajaj relied upon was not available in 1992 and,
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