Estate of H.A. True, Jr. - Page 149




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              Hank True testified that during the period 1992 through                 
          1994, Belle Fourche’s business primarily consisted of moving oil            
          for unrelated companies.  Further, Mr. Gustavson observed that              
          Belle Fourche’s average annual throughput substantially exceeded            
          the quantities of oil actually produced by the True companies.              
          Therefore, we are not persuaded that the value of a controlling             
          interest in Belle Fourche would be diminished by its                        
          interrelatedness with the True companies.                                   
              Turning to the Kimball report, we find various errors in the            
          computation of Belle Fourche’s financial fundamentals,                      
          specifically EBDIT.  According to respondent, Mr. Kimball                   
          computed EBDIT by taking ordinary income reported on page 1 of              
          Form 1120S (line 21) and by adding back interest expense (line              
          13) and depreciation (line 14c).  However, line 14c did not                 
          account for depreciation that was included in the computation of            
          cost of goods sold, reported on Schedule A.  Respondent argues              
          that total depreciation reported on line 14a, which included                
          depreciation reported on Schedule A and elsewhere on the return,            
          should have been added back to arrive at Belle Fourche’s EBDIT.71           

               71Arguably, it is possible that Mr. Kimball’s computation of           
          debt-free cash-flow (DFCF) omitted the same adjustment for                  
          depreciation that was included in cost of goods sold.  It also              
          appears that cost of goods sold for some of the years being                 
          analyzed included amortization expense that should have been                
          added back to DFCF and earnings before depreciation, interest,              
          and taxes (EBDIT).  We do not adjust for these items, however,              
          because respondent did not raise them and petitioners did not               
          have the opportunity to respond to them.                                    
                                                             (continued...)           




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