- 28 - make the negative-2-percent adjustment on the basis of petitioner’s conservative capital structure as reflected in its ample cash reserves and borrowing capacity as defined by Dr. Sliwoski, low debt-to-equity ratio, and business model to maintain consistent yearly sales. Therefore, we hold that an independent investor would find the following assumed rates of return acceptable: TYE TYE TYE Factor June 30, June 30, June 30, 2000 1998 1999 Risk-free rate 6.0% 5.4% 6.8% Equity risk premium 8.2 8.4 8.5 Size premium 3.3 2.6 4.3 Company specific (2.0) (2.0) (2.0) risk premium Assumed rate of 15.5 14.4 17.6 return The average assumed rate of return for the years in issue was 15.8 percent. 2. Time Period and Calculation The parties computed the compound growth rates of petitioner’s shareholders’ equity for 20-year and 10-year periods. Instead of using compound growth rates to determine whether an independent investor would be satisfied with the return on its investment, this Court has generally calculated a corporation’s ROE by dividing its net income after tax for a specific year by its shareholders equity. See B & D Foundations, Inc. v. Commissioner, T.C. Memo. 2001-262 (discussing the ROEPage: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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