Discounted cash flaw explanation

Court Case – Estate of Louise Paxton Gallagher, Deceased v. Commissioner of Internal Revenue  September 11, 2012 – 01:34 pm
Knowledge management reporting

Estate of Louise Paxton Gallagher, Deceased, F. Gordon Spoor, Personal Representative v. Commissioner of Internal Revenue, TC Memo 2011-148 Filed June 28, 2011, and Supplemental Memorandum Opinion issued October 11, 2011.

The Facts: 

Ms. Gallagher owned 3, 970 units of Paxton Media Group, LLC (“PMG”), at the time of her death on July 5, 2004.  As of July 2004, PMG was a publishing and media company that published 28 daily newspapers, 13 paid weekly publications, and a few specialty publications, and owned and operated a television station.  Ms. Gallagher was the largest single shareholder in PMG at the time, holding 15% of PMG’s 26, 439 outstanding units.

The estate filed Form 706 on September 30, 2005.  The return stated the value of Ms. Gallagher’s units as $34, 936, 000 or $8, 800 per unit, based on a July 12, 2004, appraisal of PMG’s units performed by PMG’s president and CEO, Mr. David Michael Paxton.

The IRS selected the return for audit and on June 13, 2007, the estate of Ms. Gallagher received a deficiency notice stating the fair market value of the PMG units owned by Ms. Gallagher was $49, 500, 000, as of the date of her death.

The estate obtained an independent appraisal of the units from Sheldrick, McGehee & Kohler, LLC (SMK), which appraised the units at $26, 606, 940.  Prior to the start of the trial, the estate hired a second appraiser, Mr. Richard May, who valued the units at $28, 200, 000, or approximately $7, 100 per unit.  Also before trial, the IRS hired Mr. John Thomson of Klaris, Thomson & Schroeder, Inc. (KTS) to perform an independent appraisal of Ms. Gallagher’s units.  Mr. Thomson determined the fair market value of the units to be $40, 863, 000, or $10, 293 per unit.

Source: Nationwide Valuations

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Well that depends on your definition of tangible

You can't touch software.
Basically, the OP stated that the mind or conciousness is not tangible. Conciousness is basically a program that runs on the hardware called the brain. If the mind is not tangible, then neither is software. In any reasonable definition of tangible, the mind and software have the same level of tangibility.
You might argue that software is stored as high and l... physical representation. You can copy a program from a magnetic disk to an optical CD. The physical representation has changed, but the software has not. You can envision the software running on an archaic computer of mechanical switches and relays. The same algorithms can run (albeit slowly), although the underlying structure is totally different. You don't even need to manipulate electricity.

Point is there IS a way to discern repeated spam

If you're not into software, I understand, it *was* pseudocode, which by definition of that term indicates a requirement on the part of the implementer to add their own knowledge to the actual coding effort...
THe entire point was this: There simply is a QUITE EASY WAY for Craig to block spam posts whose content is highly repetitive.
Will the filters need to rely on heuristic assessm...ate posting allowed" detection software IS ALREADY DEPLOYED on CL to block similar posts by the same user.
In fact -- you can't even post the same or a quite similar Rant on the RANTS-N-RAVES forum. You cannot post in LA, then try to post a similar posting in SFO's Rants-n-Raves. So the 'no duplicate posting' code is everywhere, why not here!
LET'S DEPLOY IT ON THE FORUMS TOO, CRAIG!

Deloitte & Touche LLP | OECD Releases Discussion Draft on Intangibles  — Linex Legal
The draft's broad definition of intangibles using a new, two-pronged test. The potentially controversial approach to identifying parties entitled to intangible-related returns. Identifying transactions involving the use or transfer of intangibles …

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