- 43 - We must decide the value of petitioner’s favorable financing intangible assets. Because income spread measures equity and not the value of individual assets, we find that the value of petitioner’s favorable financing intangible assets is not limited to the income spread. D. Respondent’s Argument That Taxes Reduce the Value of Favorable Financing Assuming that petitioner’s favorable financing intangible assets do have value, respondent argues that petitioner’s calculations over-valued these assets because its method failed to incorporate the effect of taxes. In his rebuttal report, Dr. Hakala explained that “the reduction in the value of the liability would be partially offset by a deferred tax liability.” Dr. Hakala calculated value by reducing the value of the intangible assets for income taxes and increasing the value by the tax shield.18 After incorporating the tax effect, Dr. Hakala prepared a summary analysis of the favorable financing intangible assets using Professor Schaefer’s market prices as follows: Debt Corrected Value G-15 $6,977,205 G-16 11,448,352 G-17 30,735,708 F-8 296,491 F-11 67,179,640 18 The reduction of value for income taxes reflects the present value of cashflows on an after-tax basis. The tax shield is the amortized tax benefit associated with creating an intangible asset.Page: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 Next
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