- 47 - 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,Page: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 Next
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