Menard, Inc. - Page 54

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               After reviewing both experts’ methodologies, we conclude               
          that Black-Scholes is a more credible stock option valuation                
          method than the Growth Model.  Unlike Mr. Rowley’s Growth Model,            
          Black-Scholes accounts for the effects of dividends and                     
          volatility on the stock options’ values.  Moreover, generally               
          accepted accounting principles support the use of Black-Scholes             
          for valuing stock options.  For example, paragraph 19 of SFAS No.           
          123 requires for financial reporting purposes that companies use            
          a fair value method of accounting, such as Black-Scholes, to                
          estimate the companies’ stock option expenses.47  Furthermore, we           
          disagree with petitioners’ contention that Black-Scholes                    
          understates the options’ values.  Considering that Black-Scholes            
          does not account for transfer restrictions, vesting periods, or             
          the risk of forfeiture, Black-Scholes more likely overstates the            
          options’ values.                                                            
               In support of Dr. Hakala’s decision to alter the Black-                
          Scholes value by taking a 50-percent discount for risk aversion,            
          respondent cites articles in accounting journals that describe              
          the valuation approach of SFAS No. 123 and discuss the prevalence           
          and implications of forfeiture and early exercise of employee               


               47Paragraph 19 of SFAS No. 123 actually recommends a                   
          slightly modified version of Black-Scholes in that the SFAS No.             
          123 model replaces the actual-time-to-expiration variable with              
          the expected life of the option.  In paragraph 169, SFAS No. 123            
          explains that this substitution reflects the restrictions on                
          transferability of employee stock options.                                  




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