- 226 - 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...)Page: Previous 216 217 218 219 220 221 222 223 224 225 226 227 228 229 230 231 232 233 234 235 Next
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