Johann T. and Johanna Hess - Page 40

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          ending July 31, 1995.  Petitioners claim that good appraisal                
          practice requires use of the same period of time for the                    
          guideline companies and the subject company.  We agree with                 
          petitioners that the preferable comparison of historical and/or             
          projected earnings should be made using consistent time periods.            
          However, petitioners do not explain how the use of consistent               
          time periods in the instant case would change Mr. Engstrom’s                
          conclusions.  Although this flaw in Mr. Engstrom’s analysis leads           
          us to question its persuasiveness, we are not convinced that it             
          renders his analysis wholly erroneous.                                      
               Mr. Engstrom relied solely on HII’s fiscal year 1995                   
          financial information in making his conclusions.  Fiscal year               
          1995 was a “banner year” for HII.  It realized sales and net                
          income exceeding the sales and net income that it realized in               
          prior years.  Petitioners contend that it was in error to rely              
          solely on the fiscal year 1995 information.  Respondent argues              
          that use of the fiscal year 1995 information alone was justified            
          because HII was experiencing strong growth, which HII’s                     
          projections indicated would continue, and “it comports with                 
          common sense that more current information and expectations are             
          more indicative of the value that an investor would place on                
          stock than are historic earnings.”                                          
               We might agree with respondent that the hypothetical buyer             
          would give primary consideration to the most recent year’s                  






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