Estate of James J. Renier, Deceased, Kent L. Renier and Dubuque Bank & Trust Company, Co-Executors - Page 22

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          experts disagree on the appropriate normalizing adjustment for              
          the correction of the inventory error.                                      
               Mr. Sliwoski believed that, since average income for the               
          69.33-month base period (including the correction years) was                
          being used, no further adjustment was necessary.  The averaging             
          of the correction years’ income with the income of the 4                    
          precorrection years (which income was almost certainly                      
          understated) would produce an accurate average for the 69.33-               
          month period, in his view.  This position effectively “spread”              
          the cost of goods sold adjustment over the 69.33-month base                 
               Mr. Kramer, however, believed that the cost-of-goods-sold              
          adjustment should be spread over 10 years, on the grounds that              
          Renier had sold the same product line for approximately 20 years            
          and “it was estimated” that the erroneous inventory method had              
          been used “for at least half of that period”.  As a result, Mr.             
          Kramer spread the cost-of-goods-sold adjustment over a 10-year              
          period and excluded from normalized income some 50.67 months’               
          worth of the adjustment which fell outside the base period.                 
               With respect to the cost-of-goods-sold adjustment, we                  
          conclude that the estate has failed to show error in respondent’s           
          approach.  The estate has offered scant evidence of the nature of           
          the inventory adjustment; there is no evidence in the record of             
          the exact nature or duration of the error in accounting for cost            
          of goods sold.  Such evidence was presumably available to the               

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