Michael T. Caracci and Cindy W. Caracci, et al. - Page 45




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          situation, the Sta-Home entities paid their employees 6 weeks in            
          arrears.  Thus, an employee was required to wait 6 weeks before             
          getting his or her first paycheck, for 2 weeks’ work.  In the               
          meantime, however, Medicare reimbursed the companies for the                
          amount of accrued wages every 2 weeks.  The entities thus                   
          received 6 weeks’ worth of wages per employee before being                  
          required to pay out 2 weeks’ worth.  The deferral of actual                 
          payment meant, in effect, that each employee made a loan of 4               
          weeks’ wages to the company, and the “loan” would not be repaid             
          until the employee left his or her employment.  When one employee           
          left, another was presumably hired, and the new employee would be           
          required to forgo 4 weeks’ salary, thus keeping the total amount            
          of deferrals relatively stable.   By 1995, this practice had                
          generated a “float” of approximately $4.1 million that the                  
          entities possessed and were not required to repay until some                
          unspecified time in the future.  It appears that 2 weeks’ worth             
          of payroll and payroll taxes is properly characterized as short-            
          term liabilities.  We conclude that the amounts of payroll that             
          were withheld for longer than 2 weeks were not, in this case,               
          properly characterized as current liabilities.  For purposes of             
          this valuation, they should be considered part of the invested              
          capital.  Accordingly, of the $6,150,000 withheld, two-thirds (or           
          4 weeks’ worth) should be excluded from the current liabilities             
          that Wilhoite added to the MVIC.  Wilhoite based his calculation            






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