A Story in Yokohama -20【moisture-loving plants】
A Story in Yokohama【 Subtitled "Longing"】-20
“I see. By the way, I heard that there is a method of evaluation by comparing the profit situation of other similar companies.”
“As you say, there is a method of evaluation called the similar industry comparison method. In addition, there is a valuation method that combines the similar industry comparison method and the net asset valuation method. And when it comes to travel agencies, there are many different types of companies in the same industry, such as a domestic travel agency, an overseas travel agency, and a travel agency which handles both domestic and overseas.”
“Can't the similar industry comparison method be used in the valuation of Milan Travel Agency?”
“No, I don't think so.”
“Why not?”
“Because there are no comparable companies that can be used. There are two types of overseas travel: travel to and from abroad, the former is called ‘outbound’, the latter ‘inbound’. Milan Travel Agency is the only travel agency that specializes in outbound, high value-added travel, based on an elaborate network in Italy and Europe. I don't know of any other travel agent that does it that way.”
“Are you sure that the net asset method, based on book value, is the right way to go?”
“I believe that is the most reasonable and conservative method of valuation in this case.”
“Can I ask you to be more specific?”
“Go ahead.”
“If I were a lawyer, I would first raise the issue of the National Tax Assessment Notice, whether it is reasonable to have a notice that changes the valuation method significantly after a 30 per cent shareholding, and then argue whether it is appropriate to bring a criminal case against the taxpayer in this case, when there are rules that make a substantial difference between taxpayers with a shareholding of 30 per cent or more and those with a shareholding of slightly less than 30 per cent. What do you think?”
“I am not at liberty to answer the purpose or rationale of the NTA's notice. If you have any questions about this, please ask the appropriate person at the NTA. However, I can give you a simplified explanation.”
“I'd like to hear your explanation.”
“As you are aware, it is essential that there is uniformity in the application of administrative law. The tax notices are designed to take this into account. If the taxpayer suffers damage as a result of the uniformity of treatment, the notice should be examined. However, in this case, there was no concern that the net asset method of valuation would lead to an overvaluation of the taxpayer's assets; on the contrary, the uniformity of the notices meant that the taxpayer's valuation would have been considerably lower than it would have been if the actual shareholding had been a little lower. So I don't think that the reasonableness or unreasonableness of the notice is ultimately going to be an issue.”
“Hmmm.... I understand. I'll give it some more thought.”
“Please do.”
“You're a tough officer. And yet you haven't been promoted much in the tax world.”
“I don't get promoted because I'm not good enough.”
“It's not enough to be a professional idiot nowadays. You have to be able to observe the structure of the organization you work for, to care about your bosses and colleagues, and to present yourself well. At least you are not making that effort.”
Fukada smiled.
“That may be true, but if I had time for that, I would do my job.”
The prosecutor said.
“A honeyed tongue with a heart of gall.”
“What?”
“I mean people who are clever with their words but not with their heart. It is not uncommon these days for people to be clever with their words.”
“I don't know what to say.”
“I like the way you work hard and don't care about promotion. One day, when I leave my job, I'd like to work with someone like you and Miss Hayashida.”
“You rate me too highly. ... Please consider the case.”
Commentary
Fukada is answering questions about the case from an old acquaintance, a prosecutor.
The prosecutor seems to approve of the competence of the female investigator and Fukada, who are both present.