The Charles Schwab Corporation and Subsidiaries - Page 43

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          measure of useful life since the Rose customers were to be                  
          integrated into petitioner’s business environment.21                        
               Mr. Knoblick then focused on Rose’s annual revenues from               
          cash and margin accounts, which were determined to be $6,183,294            
          and $6,765,276, respectively.  Those amounts were adjusted to               
          account for petitioner’s revenue growth by employing a 12-percent           
          increase over each 4-year period.  This 12-percent adjustment was           
          based on petitioner’s actual financial performance.  Thereafter,            
          pretax earnings were determined by applying the pretax profit               
          margins petitioner used in its evaluation of the Rose business              
          entity at the time of purchase.  The use of petitioner’s pretax             
          profit margins accounted for capital burden, including the fixed            
          and overhead costs of servicing the acquired Rose accounts.                 
          Applying a 34-percent Federal tax rate, Mr. Knoblick derived an             
          after-tax income stream.  He then applied a 16-percent discount             
          in order to determine the present value of the income stream.               
          Mr. Knoblick’s use of the 16-percent discount was based on its              
          use by petitioner’s acquisition team in their pre-purchase                  
          analysis of Rose.  Using that methodology, the fair market values           
          of Rose’s cash and margin customer accounts were determined to be           
          $4,130,000 and $6,711,000, respectively.                                    

               21  Petitioner followed the procedures for useful life set             
          forth in sec. 1.167(a)-1(b), Income Tax Regs., as more fully                
          discussed later in this Opinion in the section addressing useful            
          life.                                                                       





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