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2(f), Gift Tax Regs. As the trier of fact, we have broad
discretion in assigning the weight to accord to the various
factors and in selecting the method of valuation. Estate of
O'Connell v. Commissioner, 640 F.2d 249, 251-252 (9th Cir. 1981),
affg. on this issue and revg. in part T.C. Memo. 1978-191; sec.
25.2512-2(f), Gift Tax Regs.
The determination of the value of closely held stock, like
each of the two 25-share blocks of ADDI&C stock at issue, is a
matter of judgment, rather than of mathematics. Hamm v.
Commissioner, 325 F.2d 934, 940 (8th Cir. 1963), affg. T.C. Memo.
1961-347. Moreover, since valuation is necessarily an
approximation, it is not required that the value that we determine
be one as to which there is specific testimony, provided that it
is within the range of figures that properly may be deduced from
the evidence. Silverman v. Commissioner, 538 F.2d 927, 933 (2d
Cir. 1976), affg. T.C. Memo. 1974-285; Anderson v. Commissioner,
250 F.2d 242, 249 (5th Cir. 1957), affg. in part and remanding in
part T.C. Memo. 1956-178.
As is customary in valuation cases, the parties rely
extensively on the opinions of their respective experts to support
their differing views about the fair market value on the valuation
date of each of the two 25-share blocks of ADDI&C stock in
question. The estate relies on (1) Mr. Howard, who is an
accredited senior appraiser of the American Society of Appraisers
and a principal in the business valuation firm of Howard Frazier
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