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Trustee Claims Bankruptcy Court Flouted Valuation Rules

District court affirms bankruptcy court’s valuation of hospital under income approach and finds its treating a $20.6 million capital transfer as surplus rather than a necessary asset for operations is not double counting and is reasonable under the facts ...

In re Civic Partners Sioux City, LLC

The Bankruptcy Court finds the debtor’s reorganization plan is not feasible because it fails to provide enough funds to pay in full the primary creditor’s secured claim; the plan rested on an improperly low valuation of the property that makes up the majo ...

What ‘FMV’? Bankruptcy Court Restricts Car Dealer’s Damages

Bankruptcy court finds car dealer’s claim for fair market value of its franchise based on state law dealer statute is invalid under Bankruptcy Code; expert testimony only supports past lost profit damages for cars and parts and accessories in stock at tim ...

Court Approves Debtor’s ‘Feasible, But Tight’ Plan With 6% Interest Rate

In Chapter 11 proceeding, Bankruptcy Court approves debtor hotel owner’s reorganization plan over objection of creditor that holds both secured and unsecured claims; applying the “Till formula approach,” the court decides the plan’s proposed 6% “cramdown”

A new resource for your bankruptcy law library

In re Eastman Kodak Company

Bankruptcy court denies shareholders’ renewed request for an equity committee, finding neither the debtor nor its creditors are hiding value in their calculation of the total equity value of less than $500 million; expert testimony as to the allegedly und ...

Alberts v. HCA, Inc.

District court affirms bankruptcy court’s valuation of hospital under income approach and finds its treating a $20.6 million capital transfer as surplus rather than a necessary asset for operations is not double counting and is reasonable under the facts ...

Court Credits Expert’s Cash Flow Analysis in Solvency Determination

Bankruptcy Court credits trustee’s expert’s cash flow analysis in finding “billionaire” debtor was insolvent at the time she signed a guarantee for a $13 million loan defendant made to her son; because the transfer was fraudulent, the court sets aside the ...

New valuation cases added to BVLaw

Whyte v. C/R Energy Coinvestment II, L.P. (In re SemCrud)

Bankruptcy Court values Chapter 11 debtor on a going concern basis and finds the income approach is best suited to determine solvency at the time of critical financial transactions; the defendants’ expert properly relied on a contemporaneous Goldman Sachs ...

In re: American Suzuki Motor Corporation

Bankruptcy court finds car dealer’s claim for fair market value of its franchise based on state law dealer statute is invalid under Bankruptcy Code; expert testimony only supports past lost profit damages for cars and parts and accessories in stock at tim ...

In Re: LMR, LLC

In Chapter 11 proceeding, Bankruptcy Court approves debtor hotel owner’s reorganization plan over objection of creditor that holds both secured and unsecured claims; applying the “Till formula approach,” the court decides the plan’s proposed 6% “cramdown”

Expert’s ‘Unsupportable’ Inputs Undermine DCF Analysis and Credibility

District court finds expert “forced” spun-off company’s low value by calculating a DCF value that “is low in the extreme and implied an incredibly low trading multiple for the [subject]”; the expert selected “the most pessimistic projections” of future pe ...

New cases added to BVLaw this week...

Expert May Use Public Information for Company Valuation

Federal court admits experts’ determination of company’s capitalization based on publicly available information under Daubert, stating that even though using this type of information is not the preferred method, it may be acceptable when the company’s sto ...

Samson v. Western Capital Partners LLC (In re Blixseth)

Bankruptcy Court credits trustee’s expert’s cash flow analysis in finding “billionaire” debtor was insolvent at the time she signed a guarantee for a $13 million loan defendant made to her son; because the transfer was fraudulent, the court sets aside the ...

Bankruptcy Court Discredits DCF as ‘Easily Manipulated’

Bankruptcy court disapproves of DCF method as lending itself to manipulation, noting rivaling experts’ “strikingly” divergent valuations despite reliance on basically the same data and analysis.

U.S. Bank N.A. v. Verizon Communications Inc.

District court finds expert “forced” spun-off company’s low value by calculating a DCF value that “is low in the extreme and implied an incredibly low trading multiple for the [subject]”; the expert selected “the most pessimistic projections” of future pe ...

DCF "subject to manipulation," bankruptcy court says

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