Santa Monica Pictures, LLC, Perry Lerner, Tax Matters Partner - Page 246

                                        -314-                                         
               Mr. Crawford’s expert report addresses two questions:  (1)             
          Whether unused NOLs of a target company are taken into account in           
          determining its value to a hypothetical willing buyer and                   
          hypothetical willing seller; and (2) whether unused NOLs of SMHC            
          (totaling $260,098,293) had potential value to that company and             
          the amount of that value as of December 11, 1996.  Mr. Crawford             
          concluded that based on his research and experience:  (1) Unused            
          NOLs of a target company are taken into account in determining              
          the value of a target to an acquirer; and (2) NOLs of SMHC would            
          have had value to a hypothetical willing buyer and hypothetical             
          willing seller of that company prior to the transactions that               
          occurred on December 11, 1996.  He concluded that the NOLs in               
          SMHC would have had a value in the range of $620,000 to                     
          $1,245,000.  In arriving at this range, Mr. Crawford first                  
          propounded a reasonable, projected utilization of NOLs by a                 
          hypothetical acquirer; second, he applied a present value                   
          analysis to the projected utilization of NOLs back to December              
          11, 1996, using a rate (10 percent) that estimated the weighted             
          average cost of capital during that period; and third, he applied           
          a 98- to 99-percent risk-related discount to that result.215                



               215 In calculating the present value of the NOLs, Mr.                  
          Crawford discounted one year too many, causing his calculations             
          to be off by one year.  Although this error would serve to                  
          increase the range of values that Mr. Crawford determined, it               
          leads us to question the reliability of his valuation as a whole.           





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