May T. Rakow - Page 7




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          ($140,666) and an upward adjustment to bring the book value of              
          the depreciable assets to fair market value ($544,213).  He also            
          subtracted the cash value of insurance ($339,238), to be valued             
          as a nonoperating asset.  These adjustments resulted in an                  
          adjusted book value of $3,323,643 for the operating assets.  In             
          determining the adjustment to the depreciable assets,                       
          petitioner’s expert used information on book values and estimated           
          fair market values as of April 30, 1993, given to him by IHC’s              
          chief financial officer.  Petitioner’s expert believes the                  
          estimated fair market values were based on quick sale auction               
          values.  He concluded that IHC had no goodwill apart from its               
          earnings capacity.                                                          
               Petitioner’s expert next valued IHC using a capitalization             
          of earnings method.  He adjusted IHC’s pretax earnings upwards in           
          some years and downwards in others to bring Mr. Rakow’s salary in           
          line with the industry average.  Over the fiscal years 1988                 
          through 1992, this adjustment averaged 0.14 percent of revenues,            
          with a range of -0.5 to 0.5 percent of revenues.  He then                   
          selected a capitalization rate, using the market comparable                 
          approach, a buildup approach, and FMI’s experience.  For the                
          market comparable approach, petitioner’s expert chose 14 publicly           
          traded companies in construction or construction-related                    
          businesses and focused on their price/earnings (P/E) ratios.  He            
          derived each company’s 1992 year range of P/E ratios from                   





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