While we understand the motivation of the FASB to account
for all elements of the acquisition transaction at fair value, we are deeply concerned
about the practice issues that will result. The heavy reliance on expected value techniques,
use of the hypothetical market participants, the lack of observable markets,
and the obligation to affix values to “possible” and even “remote” scenarios, among
other requirements, will all conspire to create a standard that will likely prove to be
nonoperational, unauditable, representationally unfaithful, abuse-prone, costly, and
of limited (and perhaps negative) shareholder value