-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 thePage: Previous 170 171 172 173 174 175 176 177 178 179 180 181 182 183 184 185 186 187 188 189 Next
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