The major differences in the opinions offered by the expert witnesses with regard to valuation of the restaurant corporation had to do with computing "free and clear earnings", a key component in the "capitalization of income" method utilized. The gross disparity was due in large measure to two factors: (1) an overinflated adjustment by petitioners' expert to compensate for historic underreporting of income; and (2) the substitution of the much higher market-based rent for...
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