DOCSLIB.ORG

A FAMILY LIMITED PARTNERSHIP (FLP) VALUATION EXAMPLE By

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text
A FAMILY LIMITED PARTNERSHIP (FLP) VALUATION EXAMPLE By A FAMILY LIMITED PARTNERSHIP (FLP) VALUATION EXAMPLE A FAMILY LIMITED PARTNERSHIP (FLP) VALUATION EXAMPLE A FAMILYBy: LindaLIMITED B. Trugman,PARTNERSHIP CPA/ABV, (FLP) MCBA, VALUATION ASA, MBA EXAMPLE By: Linda B. Trugman, CPA/ABV, MCBA, ASA, MBA By: Linda B. Trugman, CPA/ABV, MCBA, ASA, MBA Family Limited Partnerships (FLPs) have grown in popularity as an estate planning tool and a way to depress transferFamily Limited tax values. Partnerships Business (FLPs) valuation have grownexperts in popularity should be as aware an estate of the planning issues tool involved and a wayin valuing to depress FLP transferFamily Limited tax values. Partnerships Business (FLPs) valuation have grownexperts in popularity should be as aware an estate of the planning issues tool involved and a wayin valuing to depress FLP transferinterests taxand values. how to prepare Business a report valuation that isexperts less likely should to be be challenged aware of by the the issues Internal involved Revenue in Servicevaluing (IRS)FLP or,interests if challenged, and how will to preparemore likely a report be resolved that is less in favor likely ofto thebe challengedtaxpayer. by the Internal Revenue Service (IRS) or,interests if challenged, and how will to preparemore likely a report be resolved that is less in favor likely ofto thebe challengedtaxpayer. by the Internal Revenue Service (IRS) or, if challenged, will more likely be resolved in favor of the taxpayer. Valuation analysts need to do more than focus on what discounts they can use to reduce the value of a FLP Valuation analysts need to do more than focus on what discounts they can use to reduce the value of a FLP Valuationinterest. Theana lystsFLPneed agreement to do more and thanother focus partnership on what documents discounts theymust can be usethoroughly to reduce analyzed the value before of a FLP the valuationinterest. The analyst FLPcan agreement begin to and render other an partnershipopinion of value.documents The finalmust report be thoroughly must at leastanalyzed contain before certain the valuationinterest. Theanalyst FLPcan agreement begin to andrender other an partnershipopinion of value.documents The finalmust report be thoroughly must at leastanalyzed contain before certain the valuationinformation analyst about canthe beginassignment to render- the an nature opinion of ofthe value. interest The being final valued, report must the terms at least of thecontain partnership certain agreement,information andabout the the financial assignment condition - the of naturethe entity. of the interest being valued, the terms of the partnership agreement,information andabout the the financial assignment condition- the of naturethe entity. of the interest being valued, the terms of the partnership agreement, and the financial condition of the entity. This discussion is designed as an overview of the FLP valuation process and the items to consider. It is designedThis discussion to help isyou designed prepare asvaluation an overview reports of more the FLeffectivelyP valuation and processperhaps andminimize the items the opportunity to consider. for It the is designedThis discussion to help isyou designed prepare asvaluation an overview reports of more the FLeffectivelyP valuation and processperhaps andminimize the items the opportunity to consider. for It the is designedIRS to challenge to help you your prepare opinion valuation of value. reports This more discussion effectively also and assumes perhaps minimizethat the thereader opportunity has a forbas theic understandingIRS to challenge about your FLPs. opinion Please of note value. that This FLP isdiscussion being used also as a genericassumes term that in thisthe paper.reader Many has attorneysa basic understandingIRS to challenge about your FLPs. opinionPlease of note value. that This FLP isdiscussion being used also as a genericassumes term that in thisthe paper.reader Many has attorneysa basic understandingare currently using about Limited FLPs. Please Liability note Companies that FLP is(LLC), being usedrather as than a generic Limited term Partnerships, in this paper. butMany the attorneys overall structureare currently of the using transaction Limited and Liability the valuation Companies issues (LLC), are therather same. than Limited Partnerships, but the overall structureare currently of the using transaction Limited and Liability the valuation Companies issues (LLC), are therather same. than Limited Partnerships, but the overall structure of the transaction and the valuation issues are the same. WHAT IS A FLP? A FLP is a nontaxable entity that is created and governed by statute and whose partners (bothWHAT general IS A FLP? and limited)A FLP is and a nontaxable assignees entityconsist thatmainly is createdof family and members. governed by statute and whose partners (bothWHAT general IS A FLP? and limited)A FLP is and a nontaxable assignees entityconsist that mainly is createdof family and members. governed by statute and whose partners (both general and limited) and assignees consist mainly of family members. Many of the issues that arise in appraising FLPs become legal interpretations of the partnership agreement, Many of the issuesA @ that arise in appraising FLPs become legal interpretations of the partnership agreement, Manyrather ofthan the issuesApure@ thatvaluation arise inissues. appraising Although FLPs asbecome a valuation legal interpretations analyst, it is ofimportant the partnership that we agreement, know and rather than Apure@ valuation issues. Although as a valuationA analyst,@ it is important that we know and understandrather than theApure issues,@ valuation it is imperative issues. Althoughthat we leave as athe valuation Alawyering analyst,@ to the itlawyers. is important If there that is any we doubt know in and the understand the issues,= it is imperative that we leave the Alawyering@ to the lawyers. If there is any doubt in the valuationunderstand analyst the issues,=s mind it regardingis imperative the that nature we of leave the assignment the Alawyering or the@ to terms the lawyers. of the partnership If there is any agreement, doubt in the valuation= analyst=s mind regarding the nature of the assignment or the terms of the partnership agreement, the valuationclient=s attorney analyst should=s mind be regarding the one theto explain nature ofit tothe the assignment valuation oranalyst, the terms not ofthe the other partnership way around. agreement, the client=s attorney should be the one to explain it to the valuation analyst, not the other way around. client=s attorney should be the one to explain it to the valuation analyst, not the other way around. PENALTIES: Valuation analysts should be warned that applying discounts too enthusiastically c an backfire. PENALTIES: Valuation analysts should be warned that applying discounts too enthusiasticallyA can backfire. PENALTIESSection 6701: ofValuati the IRCon analysts imposes should civil penalties be warned on thatvaluation applying analysts discounts of $1,000 too enthusiastically for Aaiding and c anabettingbackfire. an Section 6701 of the IRC imposes@ civil penalties on valuation analysts of $1,000 for Aaiding and abetting an Sectionunderstatement 6701 of of the tax IRC liability. imposes@ The civil IRS penalties could also on valuationimpose an analysts administrative of $1,000 sanction for Aaiding barring and the abetting valuation an analystunderstatementfrom submitting of tax liability. probative@ The evidence IRS could in future also IRSimpose proceedings. an administrative For these sanction reasons, barring the report the valuation must be analystunderstatementfrom submitting of tax liability. probative@ The evidence IRS could in future also IRSimpose proceedings. an administrative For these sanction reasons, barring the report the valuation must be analystpreparedfrom judiciously submitting and probative every statement evidence bein future carefully IRS documented proceedings. and For presented these reasons, in such the areport way mustthat the be valuationprepared conclusionjudiciously can and beevery replicated statement and beunderstood carefully documentedby those for whom and presented it is intended. in such a way that the valuationprepared conclusionjudiciously can and beevery replicated statement and beunderstood carefully documentedby those for whom and presented it is intended. in such a way that the valuation conclusion can be replicated and understood by those for whom it is intended. The valuation analyst should also be aware of the new appraiser penalty rules that were described in the The valuation analyst should also be aware of the new appraiser penalty rules that were described in the ThePension valuation Protection analyst Act should of 2006. also Althoughbe aware theseof the penaltiesnew appraiser specifically penalty apply rules to that valuations were described for charitable in the contributionPension Protection purposes, Act many of 2006. believe Although that they these will ultimately penalties be specifically extended to apply appraisals to valuations of property for for charitable income contributionPension Protection purposes, Act many of 2006. believe Although that they these will ultimately penalties be specifically extended to apply appraisals to valuations of property for for charitable income contributionand transfer purposes, tax purposes. many The believe penalties that they fall willinto ultimately two categories, be extended a “gross to appraisals valuation ofmisstatement” property for income
Load more

Recommended publications
  • Minority Discounts, Fair Market Value, and the Culture of Estate Taxation William S
    University of Miami Law School University of Miami School of Law Institutional Repository Articles Faculty and Deans 1997 Minority Discounts, Fair Market Value, and the Culture of Estate Taxation William S. Blatt University of Miami School of Law, [email protected] Follow this and additional works at: https://repository.law.miami.edu/fac_articles Part of the Business Organizations Law Commons, and the Tax Law Commons Recommended Citation William S. Blatt, Minority Discounts, Fair Market Value, and the Culture of Estate Taxation, 52 Tax L. Rev. 225 (1997). This Article is brought to you for free and open access by the Faculty and Deans at University of Miami School of Law Institutional Repository. It has been accepted for inclusion in Articles by an authorized administrator of University of Miami School of Law Institutional Repository. For more information, please contact [email protected]. Minority Discounts, Fair Market Value, and the Culture of Estate Taxation WILLIAM S. BLATr* I. INTRODUCTION In valuing blocks of corporate stock, courts often permit a minority discount-a reduction in value that reflects the difficulty of selling shares lacking corporate control.' The allowance of minority dis- counts encourages transactions designed to reduce transfer taxes.2 Taxpayers keep property in corporate solution, sometimes in tiered holding companies,3 and gradually transfer corporate control through multiple gifts of small blocks. Long contested by the government, 4 mi- * Professor of Law, University of Miami School of Law. I would like to thank Jack Bogdanski, Mary Coombs, Joseph Dodge, Mary Louise Fellows, John Gaubatz, Pat Gudridge, Mike Livingston, Grayson McCouch, George Mundstock, Jeff Pennell, Mark Ramseyer, Jim Repetti, Tom Robinson, Deborah Schenk, Sam Thompson, and Larry Zelenak for comments on earlier drafts of this Article.
    [Show full text]
  • Application of Minority Discount and Control Premium in Business Valuation: Estonian Evidence
    View metadata, citation and similar papers at core.ac.uk brought to you by CORE provided by DSpace at Tartu University Library UNIVERSITY OF TARTU School of Economics and Business Administration Raivo Pleer APPLICATION OF MINORITY DISCOUNT AND CONTROL PREMIUM IN BUSINESS VALUATION: ESTONIAN EVIDENCE Supervisor: Associate Professor in Finance Priit Sander Co-supervisor: Assistant in Finance Mark Kantšukov Tartu 2020 Olen koostanud töö iseseisvalt. Kõik töö koostamisel kasutatud teiste autorite tööd, põhimõttelised seisukohad, kirjandusallikatest ja mujalt pärinevad andmed on viidatud. Raivo Pleer 2 TABLE OF CONTENTS TABLE OF CONTENTS .................................................................................................. 3 Abstract ............................................................................................................................. 4 Introduction ....................................................................................................................... 5 1. REVIEW OF LITERATURE ................................................................................... 9 1.1. Minority discount and control premium ............................................................. 9 1.2. Valuation approaches ....................................................................................... 18 1.3. Factors influencing minority discount and control premium ........................... 23 2. DATA AND METHODOLOGY ............................................................................ 25 3. RESULTS AND
    [Show full text]
  • IN the SUPREME COURT of IOWA No. 11–0601 Filed June 14, 2013
    IN THE SUPREME COURT OF IOWA No. 11–0601 Filed June 14, 2013 JOHN R. BAUR, Appellant, vs. BAUR FARMS, INC. and ROBERT F. BAUR, Appellees. Appeal from the Iowa District Court for Madison County, Paul R. Huscher, Judge. Minority shareholder in a closely held farm corporation appeals from the dismissal of his suit alleging oppression. REVERSED AND CASE REMANDED WITH DIRECTIONS. Douglas A. Fulton and Allison M. Steuterman of Brick Gentry, P.C., West Des Moines, for appellant. David L. Charles of Crowley Fleck PLLP, Billings, Montana, and Mark McCormick of Belin McCormick, P.C., Des Moines, for appellees. 2 HECHT, Justice. A minority shareholder of a family farm corporation sued the corporation and its majority shareholder, who served as a director and officer of the corporation. The minority shareholder alleged illegal, oppressive, malicious, and fraudulent acts by the majority shareholder had resulted in waste of the corporation’s assets and constituted a breach of fiduciary duty. The minority shareholder requested dissolution of the corporation or payment of the fair value of his ownership interest. The district court dismissed the action at the conclusion of the minority shareholder’s presentation of evidence in a bench trial. The minority shareholder appeals, contending the district court erred in dismissing the action. We reverse and remand with instructions. I. Factual and Procedural Background. Baur Farms, Inc. (BFI) is a family farm corporation formed in 1966 by brothers Merritt and Edward Baur. At the time of its organization, the corporation took ownership of 1736 acres of land previously farmed by the brothers as partners.
    [Show full text]
  • PSU Disinvestment Valuation Guidelines
    Valuation Methodology CONTENTS CHAPTER I Introduction CHAPTER II Disinvestment Commission's Recommendations CHAPTER III Valuation Methodologies being followed Standardizing the valuation approach & CHAPTER IV methodologies CHAPTER - 1 Introduction 1.1 In any sale process, the sale will materialize only when the seller is satisfied that the price given by the buyer is not less than the value of the object being sold. Determination of that threshold amount, which the seller considers adequate, therefore, is the first pre-requisite for conducting any sale. This threshold amount is called the Reserve Price. Thus Reserve Price is the threshold amount below which the seller generally perceives any offer or bid inadequate. Reserve Price in case of sale of a company is determined by carrying out valuation of the company. In companies which are listed on the Stock Exchanges, market price of the shares serves as a good benchmark for assessing the fair value of the company, though the market price is usually characterized with significant short-term variance due to investor sentiments being influenced by short-term events and environmental aspects. More importantly, most of the PSUs are either not listed on the Stock Exchanges or command extremely limited traded float. They are, therefore, not correctly valued. Thus, deciding the worth of a PSU is indeed a challenging task. 1.2 Another point worth mentioning is that valuation of a PSU is different from establishing the price for which it can be sold. Experts are of the opinion that valuation must be differentiated from price. While the fair value of an asset is based on the assessment of intrinsic value accruing from fundamentals on a stand-alone basis, varying return expectation and underlying strategic aspects for different bidders could influence the price.
    [Show full text]
  • The Process of Valuation – Placing Value on Your Business
    Article: Placing value on your business The process of valuation – Placing value on your business On a regular basis, business owners, investors and experienced bankers look for a simple way to determine business value: a rule of thumb or formula. Hoping to avoid the expense and trouble of hiring a professional valuator, a value formula common to the business type is used; thereby assuming determination of a company’s value can’t be complicated. While using a rule of thumb may be a considered alterative in developing a rough test price, it provides a weak form of market comparison for business value; relying solely on this approach poses inherent problems. However, the rule of thumb approach typically employs a multiple of cash flow (or EBITDA = Earnings Before Interest, Taxes, Depreciation and Amortization) and/or a multiple of revenues. Business valuation is the act or process of determining value of a business enterprise or ownership interest therein. Valuation of a security interest in a closely held business is a difficult process due to the lack of an active free trading market. Because of the absence of such a market, an underling notion in valuing closely held businesses is found in the investment value principle. The principle suggests the purchase of an equity interest in a closely held business should be viewed like any other investment. In essence, the “investor” not only expects to receive the initial investment back, but also receive a fair return on the investment commensurate to the risk incurred. The investment value principle can be express as a formula, illustrated as follows: Investment Value Principle Benefit Value = Risk Hodges & Hart, LLC Page 1 Certified Public Accountants Article: Placing value on your business Where, Value = the investment value of the business (present value).
    [Show full text]
  • Control Premiums and Minority Discounts
    Advanced Discounts and Premiums CONTROL PREMIUMS/MINORITY DISCOUNTS CHAPTER TWO CONTROL PREMIUMS AND MINORITY DISCOUNTS Chapter Objectives 1. Identify the advantages of maintaining a controlling equity interest in a privately held enterprise. 2. Recognize the factors that influence various levels of control. 3. Differentiate between fundamental arguments both for and against the use of control premiums. I. INTRODUCTION Of all the intrinsic characteristics related to an equity interest, arguably none may be more important than the element of control. Widely accepted theory within the business valuation community holds that an investment in a privately held company is worth the present value of all of the future benefits inuring to the holder of that equity interest. Clearly, then, if the equity holder has a control position, he or she can accelerate the receipt of those future benefits and via management and operational initiatives, take direct steps to enhance the future benefits—or at least the probability that they will be generated. On the other hand, a minority or non-controlling position in a privately held company is generally held at the great risk of being subject to the judgment, ethics, and management skills of the control shareholder(s). Depending on a number of items, the impairment of value can be significant in this circumstance. It is not proper to use the term minority discount in all cases. A minority discount is a discount for lack of control applicable to a minority interest. A discount for lack of control is an amount or percentage deducted from the subject pro rata share value of 100% of an equity interest to compensate for the lack of any or all powers afforded a control position in the subject entity.
    [Show full text]
  • Application of Share-Price Discounts and Their Role in Dictating Corporate Behavior: Encouraging Elected Buy-Outs Through Discount Application
    WLR43-1_RABBAT_EIC_FINAL_11-3-06 11/25/2006 4:42:21 PM APPLICATION OF SHARE-PRICE DISCOUNTS AND THEIR ROLE IN DICTATING CORPORATE BEHAVIOR: ENCOURAGING ELECTED BUY-OUTS THROUGH DISCOUNT APPLICATION ROBERT A. RABBAT ∗ Introduction......................................................................................108 I. Shareholder Oppression ...........................................................109 A. The Close Corporation....................................................109 B. Reaction to Oppressive Behavior ...................................110 C. Reaction of the Controlling Shareholder ........................112 i. Action for Involuntary Dissolution...........................113 ii. Election to Buy-Out the Minority Shareholder.........114 iii. The Cash-Out Merger ...............................................114 II. When is Fair Value Relevant?..................................................115 A. Involuntary Dissolution Statutes ....................................116 B. The Buy-Out Remedy.....................................................118 C. Fair Value in Dissenter’s Rights (Appraisal) Statutes....119 D. Is Fair Value Identical Regardless of the Context? ........120 III. What is Fair Value?..................................................................120 A. Not Fair Market Value....................................................121 B. Fair Value is an Approximation of Fair Market Value...122 IV. Introducing Share-Price Discounts ..........................................123 A. Minority Discounts.........................................................124
    [Show full text]
  • Business Breakups: Terminating Ownership Interests in Closely Held Businesses Robert J
    Shareholder Litigation Insights Business Breakups: Terminating Ownership Interests in Closely Held Businesses Robert J. McGaughey, Esq. In the current market, liquidity is everywhere. Large banks pooled mortgages that converted illiquid mortgage notes into liquid securities. Buying and selling stocks is easier and less expensive than ever. However, one investment class that has not seen increased liquidity is investments in closely held businesses. Although these investments may provide owners with pride, a job, or above-market returns, investments in closely held businesses are among the least liquid investments available. Forensic analysts, legal counsel, business owners, and the Internal Revenue Service are often concerned with how quick, how easy, at what price, and at what cost, the owner of a noncontrolling ownership interest in closely held company can sell his or her shares? This discussion presents some of the more common methods available to both controlling owners and noncontrolling owners to sell or otherwise dispose of their investment in the closely held company. As summarized throughout this discussion, there are limited methods for noncontrolling owners to cash out of their investment in a closely held company. Most methods available to noncontrolling owners involve litigation, which can be costly and can involve an uncertain outcome. NTRODUCTION Throughout this discussion, Oregon is used to I provide illustrative examples of methods to termi- When owners of minority interests become dissatis- nate ownership interests in closely held businesses. fied with those in corporate control of a publicly trad- Every state has unique statutes and case law with ed corporation, those owners can simply sell their regard to terminating ownership interests in closely shares and immediately terminate their relationship held businesses.
    [Show full text]
  • CLE-Book Quantification & Application of Valuation Discounts
    Attorney CLE Series Quantification & Application of Valuation Discounts UNDERSTANDING THE USES AND MISUSES OF DISCOUNTS FOR LACK OF CONTROL AND LACK OF MARKETABILITY October 26, 2011 Presented by the Business Valuation Services Group IRS Circular 230 Notice To ensure compliance with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice contained in this presentation is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommend- ing to another party any transaction or matter addressed in this presentation (or in any attachment). This presentation is intended only for the participant. It may contain information which is confidential. If you are not a registered participant, you are hereby notified that any disclosure, copying, distribution, use, or any action or reliance on this presentation is strictly prohibited. Attorney CLE Series – October 26, 2011 Robert J. Grossman, CPA /ABV , ASA , CVA , CBA ob heads our firm’s Tax and Business Valuation Groups. He brings extensive Bexperience in tax and valuation matters that affect businesses, both public and private, as well as the stakeholders and owners of these businesses. The breadth of his involvement encompasses the development and implementation of innovative business and financial strategies designed to minimize taxation and maximize owner wealth. As his career has progressed, Bob has risen to a level of national prominence in the business valuation arena. His expertise in business valuation is well known, and Bob is a frequent speaker, regionally and nationally, on tax and valuation matters.
    [Show full text]
  • 14-1 Dishing the Dirt on Planning for Real Estate
    DISHING THE DIRT ON PLANNING FOR REAL ESTATE INVESTORS Farhad Aghdami1 Williams Mullen, P.C. Richmond, Virginia I. INTRODUCTION. A. Real Estate Owners and Family Businesses. 1. Real estate owners share all of the problems of the family business owner, in addition to the unique problems of owning real estate. However, real estate presents some opportunities that other family businesses do not share. 2. There are three basic goals of estate and gift tax planning for real estate: (a) the reduction of estate and gift taxes upon transfer; (b) the deferral of the estate and gift tax burden; and (c) the provision of the necessary liquidity to pay the taxes imposed on an illiquid asset. 3. Furthermore, while taxes cannot be ignored when planning for real estate, additional goals for the real estate owner, which can be as important as tax planning, include (a) creditor protection, (b) retention of control over the real estate by the client, (c) management succession, and (d) economic support of the family. B. Valuation Discounts. The estate planning goals means that the planner for a real estate owner will be grappling with the discounts in valuation available to limited partnerships and limited liability companies, since the real estate owner will already be using these entities for business purposes. These discounts are much more easily obtained for the real estate owner, in light of the real estate assets held in the entity (as opposed to passive stock portfolios), but the extent of these discounts will still be subject to attack by the Service. C. Management Succession.
    [Show full text]
  • MINORITY and LIQUIDITY DISCOUNTS - an UPDATE Canadian Institute of Chartered Business Valuators (CICBV) James P
    MINORITY AND LIQUIDITY DISCOUNTS - AN UPDATE Canadian Institute of Chartered Business Valuators (CICBV) James P. Catty © 1995 Our subject this evening, Minority and Liquidity Discounts, is one that.in recent years has attracted much attention. Richard Wise, a past president of the CICBV, spoke on the subject at the 1990 Vancouver conference, and Joel Adelstein, another past president, summarized the current position last June at the Quebec City Conference. In between, the Business Valuation Review has published contributions by John D. Emory (December 1990), Mary Ann Leach (March 1991), David W Simpson (March and June 1991) and William C. Herbert, Patrick K. Schmidt and Robert J. Strachota (September 1992). In preparing this paper, I have used all their published works, as well as one Canadian study everyone seems to have overlooked. This is "The Feasibility of Implementing Minority Discount Factor Guidelines in the Valuation of Minority Interest Shareholdings in Private Corporations"; it was released by Deloitte, Haskins & Sells ("DH & S" now Deloitte & Touche), in October 1978. At that time, I was managing the DH & S valuation group, and supervised the study; unfortunately, I and the principal researcher left the firm shortly afterwards, and the study seems to have been totally forgotten. Even though it has how reached the impossible teens, its conclusions appear still valid fourteen years later. Before looking at our subject, I must confess a certain bias. I started business valuations in the mid 1950,s. The first I undertook in Canada related to supporting the capitalized costs of a uranium mine, using a Discounted Cash Flow method.
    [Show full text]
  • Business Valuation Discounts and Premiums
    Business Valuation Discounts and Premiums SECOND EDITION Shannon P. Pratt E1FFIRS 03/10/2009 11:19:30 Page 2 E1FFIRS 03/10/2009 11:19:30 Page 1 Business Valuation Discounts and Premiums E1FFIRS 03/10/2009 11:19:30 Page 2 E1FFIRS 03/10/2009 11:19:30 Page 3 Business Valuation Discounts and Premiums Second Edition SHANNON P. PRATT John Wiley & Sons, Inc. E1FFIRS 03/10/2009 11:19:31 Page 4 This book is printed on acid-free paper. 1 Copyright # 2009 by John Wiley & Sons, Inc. All rights reserved. Published by John Wiley & Sons, Inc., Hoboken, New Jersey. Published simultaneously in Canada. No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, electronic, mechanical, photocopying, recording, scanning, or otherwise, except as permitted under Section 107 or 108 of the 1976 United States Copyright Act, without either the prior written permission of the Publisher, or authorization through payment of the appro- priate per-copy fee to the Copyright Clearance Center, Inc., 222 Rosewood Drive, Danvers, MA 01923, 978-750-8400, fax 978-646-8600, or on the web at www.copyright.com. Requests to the Publisher for permission should be addressed to the Permissions Department, John Wiley & Sons, Inc., 111 River Street, Hoboken, NJ 07030, 201-748-6011, fax 201-748-6008, or online at http://www.wiley.com/go/permissions. Limit of Liability/Disclaimer of Warranty: While the publisher and author have used their best efforts in preparing this book, they make no representations or warranties with respect to the accu- racy or completeness of the contents of this book and specifically disclaim any implied warranties of merchantability or fitness for a particular purpose.
    [Show full text]