- 12 - reported net income in order to “normalize” it; that is, to convert Renier’s historical average net income into income that a hypothetical purchaser could expect in the future, by eliminating anomalous transactions and capital structures. However, the experts exhibited significant differences regarding the necessary “normalizing” adjustments. They also had significant differences in computing the capitalization rate that should be applied to normalized income and, to a lesser extent, differences in the methodology for valuing Renier’s nonoperating assets. The foregoing differences produced dramatically different results. Mr. Sliwoski valued Renier’s operating assets at $1,293,760, to which he added his estimate of the value of Renier’s nonoperating assets of $553,938,5 for a total value of $1,847,698 on the valuation date. Mr. Kramer’s income approach, by contrast, resulted in a value for Renier’s operating assets of $450,104; i.e., an amount approximately two-thirds lower than Mr. Sliwoski’s computation. The difference in Mr. Kramer’s estimate for Renier’s nonoperating assets was not as dramatic; Mr. Kramer’s estimate was $470,9256 versus Mr. Sliwoski’s $553,938. 5 Although Mr. Sliwoski recognized he had double counted a liability of $137,038, he did not modify his computations to correct for this error. Had he done so, Renier’s nonoperating assets would have increased by $137,038, and its total value would have equaled $1,984,736. In any event, respondent has not sought an increase in his deficiency determination in connection with this error. 6 Unlike Mr. Sliwoski’s value for nonoperating assets, this (continued...)Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011