Santa Monica Pictures, LLC, Perry Lerner, Tax Matters Partner - Page 108

                                        -189-                                         
          Mr. Medress assumed a 20-percent return rate, which he regarded             
          as “typical of sell-through product.”140                                    
               Because of the age of the EBD film titles, Mr. Medress                 
          selected a $44.95 wholesale price for rental units, which was at            
          the lower end of the range for direct-to-video titles released by           
          independent studios.  On the basis of his industry knowledge, Mr.           
          Medress used a $7.99 wholesale price for sell-through units.                
               Mr. Medress did not incorporate a release pattern into his             
          projections; he assumed that income would be received evenly over           
          his 10-year projection period (with the exception of the annual             
          2.5-percent decay rate discussed above).                                    
               Incorporating these figures, Mr. Medress computed gross                
          sales data for the EBD film library on a year-by-year basis.                
                    ii.  Cost Projections                                             
               On the basis of his industry knowledge, Mr. Medress                    
          projected $2.75 in manufacturing, packaging, and shipping costs             
          per unit and marketing costs equal to 10 percent of gross sales.            
          Mr. Medress also projected administrative overhead at what he               








               140 Mr. Medress assumed that 98 percent of returned units              
          would be recycled into sales; he made an adjustment in the                  
          following year for the manufacturing costs of the returned units.           





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