Buckley v. Carlock

BVLaw
Full Text of Court Cases
February 28, 2022
5511 Motor Vehicle Dealers (New and Used)
441110 New Car Dealers
shareholder dissent/oppression
fair value, net asset value, normalization, shareholder oppression, auto dealership, valuation methodology, dissolution, blue sky

Buckley v. Carlock
2022 Tenn. App. LEXIS 75; 2022 WL 593549
US
State Court
Tennessee
Court of Appeals
Adam Lawyer, Scott Womack
W. Neal McBrayer, Andy D. Bennett, Arnold B. Goldin

Summary

The Tennessee appellate court affirmed the Chancery Court’s determination of the value of an oppressed minority shareholder’s interest in an “ultra-high-end” car dealership. The valuation of an expert utilized the “blue sky method,” a rule of thumb method, to value the dealership and ultimately the minority interest. The Chancery Court conducted a hearing on which it heard valuation expert testimony. The appellate court affirmed the Chancery Court’s valuation and its methodology since it was generally accepted by the financial community.
Buckley v. Carlock
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See Also

Appellate Court Affirms Use of the ‘Blue Sky Method,’ a Rule of Thumb, to Value a Minority Interest in an Oppression Case

The Tennessee appellate court affirmed the Chancery Court’s determination of the value of an oppressed minority shareholder’s interest in an “ultra-high-end” car dealership. The valuation of an expert utilized the “blue sky method,” a rule of thumb method, to value the dealership and ultimately the minority interest. The Chancery Court conducted a hearing on which it heard valuation expert testimony. The appellate court affirmed the Chancery Court’s valuation and its methodology since it was generally accepted by the financial community.