Santa Monica Pictures, LLC, Perry Lerner, Tax Matters Partner - Page 110

                                        -190-                                         
          termed an “appropriate” rate of 10 percent of gross sales.141               
          Mr. Medress did not project any conversion costs.                           
                    iii.  Net Cashflows                                               
               After deducting manufacturing, packaging, shipping, and                
          marketing costs, Mr. Medress derived net receipts for the EBD               
          film library from its projected distributions in the rental and             
          sell-through markets for each of the years in the 10-year                   
          projection period.  Mr. Medress combined the net receipts for the           
          rental and sell-through distributions and subtracted his                    
          projected overhead from these yearly figures.                               
               Mr. Medress calculated a terminal value for the EBD film               
          library based on projected cashflows for 2006, assuming that                
          units shipped would continue to decline beyond 2006 at an annual            
          rate of 2.5 percent.  Mr. Medress then computed the total                   
          cashflows for each year in his projection period, including the             
          terminal value of the EBD film library in his 2006 projections.             
          Mr. Medress applied a 44.5-percent (combined Federal and New York           
          State) tax rate and added an amortization tax benefit for each of           






               141 Mr. Medress projected overhead for the EBD film library            
          at a rate that he regarded as “typical” of a small distribution             
          company.  He assumed that the EBD film library was, or would be,            
          part of a business that distributed other films, resulting in               
          lower overhead costs.                                                       





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