- 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) thePage: Previous 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 Next
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