- 13 - Moreover, we believe the size of Dr. Shapiro’s sample was sufficiently large to make tolerable any dissimilarities between the partnership and the REITs in his guideline group. See McCord v. Commissioner, supra at 385. Petitioner complains that Dr. Shapiro’s guideline group is inappropriate because Green Street derived NAVs using a valuation method different from that used to value the partnership’s real estate. The valuation method used by Green Street, however, appears similar to that used to value the partnership’s real estate.8 In any event, even if the valuation methods are not identical, insofar as each method is reliable and unbiased (and petitioner does not contend that either is not), each might be expected to produce reasonable valuations so as to provide a meaningful basis for comparing share prices to net asset values. b. Price-to-NAV Discounts i. Petitioner’s Expert To determine the NAVs of his seven guideline companies, Mr. Oliver reviewed their reported book values and then made what his expert report tersely describes as “certain adjustments” to adjust these book values upward to reflect “appraised values 8 The parties generally agree that Green Street derived its NAVs in large part by applying various capitalization rates to the real estate net operating income generated by each company’s portfolio. The appraisal report upon which the agreed-upon value of the partnership’s real estate is based reflects a similar valuation method based on a discounted cashflow analysis of the partnership’s net rental income stream.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011