Most valuation analysts will not use a calculation report in court. But what if the other side has nothing? In an Alaska divorce case, the husband did not engage a valuation expert for his steel fabricating business, but the wife did. Her expert did a calculation of value and came up with a range of values because of problems with the underlying data. The trial court took an average of the range to determine the value for purposes of the marital estate.

Affirmed: On appeal to the state’s Supreme Court, the husband did raise any issue with the calculation report, but he argued that the court should not have used an average, citing a case (Lundquist v. Lundquist) But that case “does not require a ‘bullseye figure,’ nor does it foreclose averaging valuations in every case,” so the average value was affirmed.

The husband also argued that the trial court improperly included goodwill in the business value without first determining whether the goodwill was marketable. But the Supreme Court did not entertain that argument because the husband did not bring that issue up during the regular trial.

The case is B.M. v. R.C., 2023 Alas. LEXIS 102, and a case analysis and full court opinion are on the BVLaw platform.