- 19 -
ii. Nammacher’s Testimony
Nammacher testified that: (1) He has always tax-affected S
corporation income for the past 20 years;11 (2) an informal poll
at a recent conference showed 90 to 95 percent of responding
appraisers tax-affect S corporation income; (3) the American
Society of Appraisers (ASA) Board of Review rejects any
application for certification if the candidate submits test
answers or reports for review that do not tax-affect S
corporation income; (4) his experience is that all bankers,
investment bankers, and business brokers use tax-affecting in
estimating the value of S corporation stock; and (5) Empire uses
tax-affecting in valuing S corporation stock held by employee
stock ownership plans (ESOP) that it submits to the Department of
Labor.
We give little weight to Nammacher’s testimony about an
informal poll at an unidentified conference held on a date not
stated in the record. Nammacher admitted that ASA has never
issued an official directive or recommendation on tax-affecting S
corporations’ earnings.
Nammacher’s claim that ASA’s Board of Review rejects test
answers or reports by a candidate applying for ASA certification
11 Nammacher’s testimony about whether the tax-affecting
adjustment was based on individual or corporate income tax rates
was vague and suggests that Empire applied tax-affecting based on
C corporation income tax rates.
Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NextLast modified: May 25, 2011