In Jones and Laughlin vs. Pfeifer, the Supreme Court allowed an option for projection earnings and the appropriate discount rate:

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In Jones & Laughlin vs. Pfeifer, the Supreme Court endorsed a flexible approach to calculating future earnings and selecting an appropriate discount rate, allowing for the use of different methods depending on the specifics of the case, which includes the case-by-case method, below market discount method, and total-offset method.

In Jones and Laughlin Vs