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eliminate any advantage that Godfrey had. The estate’s
arguments, however, do not explain away Godfrey’s long-
established financial successes, good worker relationships,
extensive and loyal dealer marketing relationships, and good
reputation for product and service. Although neither party
attempted to isolate or separately value those aspects, they
represent some of the reasons for Godfrey’s past success and,
likewise, reasons for the potential for future success. The
long-established ability of the entity to earn income and profit
render inappropriate the use of a net asset approach to value
Godfrey.
Accordingly, like Mr. Burns, we give no weight to the net
asset approach in considering the value of Godfrey. We also
generally agree with Mr. Dorman’s view that the comparables were
not a good fit with this company. Similarly, Mr. Burns did not
rely on or factor in the market approach in reaching his value
for Godfrey.
It would appear that the income approach is the best
approach for valuing Godfrey, a long-established, financially
successful, closely held operating company that has shown
consistent profit and growth. In that regard, we adopt Mr.
Burns’s 10-percent discount rate, which translates into a 10-
percent capitalization rate. We do not, however, adopt the
normalized value approaches adopted either by Mr. Burns or Mr.
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