- 30 - evidence in the record reflects that this was the partnership’s only asset and source of income. Thus, the proper net present value analysis in this case should be for a term of 25 years. Although Mr. Horvey’s calculations are helpful through the year 2005, his ultimate conclusion based on a 50-year cashflow analysis is misplaced. Respondent’s argument that the appropriate discount rate to apply is 18.96 percent is based on the report and testimony of Ken D. Howell (Mr. Howell), a petroleum engineer. Mr. Howell is currently responsible for conducting independent examinations of tax returns filed by large organizations. His duties require knowledge of engineering valuation principles, tax law, and industry practice, and for the last 12 years he has prepared written technical and valuation reports to taxpayers. Mr. Howell used the buildup method18 to arrive at a discount rate he felt was appropriate. Mr. Howell stated that the average rate of return on a 20-year U.S. Government bond in 1980 was 11.36 percent (which would be the risk-free rate of return for 1980). Mr. Howell felt that it was appropriate to add an equity risk premium to this figure to arrive at the discount rate. Using historical data published in Stocks, Bonds, Bills, and 18According to Mr. Howell, the buildup method is an additive model in which the return on an asset is estimated as the sum of a risk-free rate and appropriate risk premiums, such as equity risk and firm size risk.Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
Last modified: May 25, 2011