- 25 - e. Inclusion of Interest Expense Because Mr. Sliwoski used a capitalization rate that incorporated an assumed cost of debt that a purchaser of decedent’s interest would incur to effect the purchase, he was required for consistency to add back Renier’s interest expense to his income base, so that normalized income would approximate the investment return available to both equity and debt. Mr. Kramer used a simpler “return on equity” to formulate the capitalization rate he employed. As more fully discussed infra, we conclude that the appropriate capitalization rate is a simple return on equity as used by Mr. Kramer, since the interest being valued here is an equity interest. Accordingly, it is not appropriate to add back Renier’s interest expense when computing expected future income available to equity alone. f. Adjustment for Income Taxes Both experts account for the effect of income taxes as part of normalizing Renier’s income. Mr. Sliwoski normalized reported pretax net income and then adjusted for Federal and State income taxes at an assumed combined rate of approximately 38 percent, whereas Mr. Kramer used reported after-tax net income, and then adjusted for income taxes associated with the net impact of the normalizing adjustments using the average of the actual combined Federal and State income taxes paid by Renier over the base period. Mr. Sliwoski provided no justification for his assumed rate, while Mr. Kramer’s rate reflected Renier’s historicPage: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
Last modified: May 25, 2011