- 43 - 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.Page: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 Next
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