-180-
billion in tax attributes that the Ackerman group acquired in the
transaction.
In the discussion that follows, we explain in detail the
basis for our conclusion that SMHC’s three assets (the EBD film
library, the Carolco securities, and the unused NOLs) had no
significant value at the time of the transaction in question.
3. EBD Film Library
The parties have offered expert witnesses to opine on the
value of the EBD film library at the time of the transaction in
question. As explained below, after carefully considering this
expert testimony, we conclude that the EBD film library had no
significant value at the time of the transaction in question.
a. Petitioner’s Expert
Steven L. Wagner is a principal at Deloitte & Touche. He
specializes in business valuation and issues relating to the
entertainment industry. Mr. Wagner is accredited by the
Association for Investment Research and Management as a chartered
financial analyst, is an accredited member (business valuation)
of the American Society of Appraisers, and has participated in
the financial advisory services industry for more than two
decades.
Mr. Wagner submitted an expert report appraising, as of
December 11, 1996, the 65 film titles that CLIS contributed to
SMHC on December 10, 1996. His report assumes: (a) That all the
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