- 44 -
F-12 176,830
F-13 50,628,337
F-15 203,957
F-18 112,856
D-2 4,594,048
Z-2 14,598,063
Z-3 1,039,813
ND 405,439
CD-1 6,538,498
GMC A 1975 6,194,495
GMC B 1975 3,592,694
GMC A 1976 4,299,020
GMC B 1976 6,551,705
GMC A 1977 6,524,267
GMC B 1977 9,891,261
GMC C 1977 12,890,475
GMC A 1978 18,287,188
GMC B 1978 9,347,594
GMC C 1978 7,361,840
GMC A 1979 6,486,039
GMC B 1979 5,043,839
GMC C 1979 6,737,022
CMO A-2 4,862,086
CMO A-3 8,187,424
CMO C-4 420,731
Total 311,612,917
Petitioner argues that its market-based valuation approach
integrates the effect of taxes into the value of an asset. In
other words, petitioner argues that the market prices of its debt
instruments already reflect the tax considerations of buyers and
sellers.
In his rebuttal report, Dr. Hakala quoted the following
excerpt from “Assets Acquired in a Business Combination to be
Used in Research and Development Activities: A Focus on
Software, Electronic Devices, and Pharmaceutical Industries”
(2001) by the AICPA’s IPR&D Task Force: “The task force believes
that the valuation of an intangible asset would include (a) the
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