May T. Rakow - Page 10




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          record.  Ultimately, petitioner’s expert concluded that a pretax            
          P/E ratio of 4 is appropriate in this case, as it implies a                 
          pretax investment return in the absence of growth of nearly 25              
          percent, a return allegedly consistent with FMI’s experience.               
               Petitioner’s expert then applied this P/E ratio of 4 to                
          various average and weighted average historic pretax earnings, to           
          current pretax earnings, and to projected 1993 pretax earnings as           
          estimated by IHC management.  As shown below, the results of the            
          earnings approach were lower than the value of the operation                
          derived through the asset approach.                                         
                         Method                                   Valuation           
          Book value (9-30-92)                                   $3,058,101           
          Adjusted book value (9-30-92)                          3,323,643            
          Capitalization of 5-yr. average adjusted earnings      1,820,712            
          Capitalization of 5-yr. weighted avg. adj. earnings    2,128,296            
          Capitalization of 3-yr. average adjusted earnings      2,408,588            
          Capitalization of 3-yr. weighted avg. adj. earnings    2,355,660            
          Capitalization of 1993 projected earnings              2,000,000            
          It was petitioner’s expert’s opinion that the fair market value             
          of IHC as an enterprise was $2,750,000.  When added to the                  
          nonoperating assets of $339,238, this resulted in a total value             
          for IHC on a majority basis of $3,089,238.                                  
               Petitioner’s expert determined a minority discount by                  
          consulting market data.  Using the median premiums paid for                 
          control for each year from 1980 to 1992 according to Mergerstat             
          Review, petitioner’s expert calculated the corresponding implied            
          minority interest discounts.  These discounts ranged in value               





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