- 14 - The estate contends that Shriner’s estimates of WSA’s prospective net cashflows are before corporate tax. The estate also contends that Shriner properly converted the capitalization rate from an after corporate tax rate to a before corporate tax rate to match estimated prospective net cashflows and that the conversion increased his capitalization rate from 20.53 percent to 31.88 percent. We disagree with the estate on both points. We disagree that Shriner’s estimates of WSA’s prospective net cashflows are before corporate tax because it is appropriate to use a zero corporate tax rate to estimate net cashflow when the stock being valued is stock of an S corporation. Gross v. Commissioner, supra. WSA is an S corporation, and its cashflows are subject to a zero corporate tax rate. Thus, Shriner’s estimates of WSA’s prospective net cashflows are after corporate tax (zero corporate tax rate) and not before corporate tax as the estate contends. We disagree that Shriner properly converted the capitalization rate because there was no need to do so. The parties agree that Shriner’s estimated capitalization rate (before he converted it to before corporate tax) is an after corporate tax rate. Thus, as in Gross, the tax character of Shriner’s estimate of WSA’s prospective net cashflows matches that of the unconverted capitalization rate because both are after corporate tax. It follows that Shriner should not havePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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