Estate of Josephine T. Thompson, Deceased, Carl T. Holst-Knudsen and the Bank of New York, Executors - Page 47

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               a firm’s value * * *.  [Damodaran, Damodaran on Valuation 16           
               (1994).]                                                               

          and further:                                                                

               Since the selection of comparable firms has such a                     
               paramount role in valuation with multiples, special                    
               attention must be paid to selecting a true comparable                  
               sample of firms -- firms that are in the same industry,                
               employ the same technology, apply to similar                           
               clienteles, are of similar size, and so on.  * * *                     
               [Benninga & Sarig, Corporate Finance A Valuation                       
               Approach 330 (1997).]                                                  

               We reject respondent’s expert’s 11 companies as comparable             
          to TPC.  See Estate of Clarke v. Commissioner, T.C. Memo. 1976-             
          328, where we rejected public companies as comparable,                      
          explaining as follows:                                                      

               the fact that two companies are both part of the same                  
               general industry does not, as respondent’s expert                      
               implies, make them comparable per se.  Such a standard                 
               clearly ignores the interplay of the myriad of complex                 
               factors and features that must be accounted for in any                 
               meaningful comparison.  Rather we think it imperative                  
               that the characteristics of the subject company and the                
               purportedly comparable company relevant to the question                
               of value be isolated and examined so that a significant                
               comparison can be made.  Those factors include the                     
               respective products, market, management, earnings,                     
               dividend paying capacity, book value, and position in                  
               the industry of each company.  See Cent. Trust Co. v.                  
               United States, 305 F.2d 393 (Ct. Cl. 1962).  [Emphasis                 
               added.]                                                                

               Also, we reject respondent’s expert’s discounted cashflow              
          analysis.  As explained, significant errors were made therein,              







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