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Fabrics, Inc. v. Commissioner, 202 F.2d 105, 107 (2d Cir. 1953),
affg. a Memorandum Opinion of this Court dated January 22, 1951.
Moreover, while we may accept the opinion of an expert in its
entirety, Buffalo Tool & Die Manufacturing Co. v. Commissioner,
supra at 452, we may be selective in the use of any part of such
opinion, or reject the opinion in its entirety, Parker v.
Commissioner, supra at 561. Finally, because valuation
necessarily results in an approximation, the figure at which this
Court arrives need not be one as to which there is specific
testimony if it is within the range of values that may properly
be arrived at from consideration of all the evidence. Silverman
v. Commissioner, supra at 933; Alvary v. United States, 302 F.2d
790, 795 (2d Cir. 1962).
1. Respondent's Expert
Respondent relies on the expert report of Hugh Jackson
Shelton (Mr. Shelton). Mr. Shelton has been employed by
respondent as a valuation engineer since 1987, in which time he
has completed approximately 10 business valuations. Mr. Shelton
holds a bachelor of science degree in industrial engineering from
the University of Tennessee and a master of arts degree in
business management from Webster University.
In the expert report submitted by respondent, Mr. Shelton
represents that he has certain qualifications and credentials to
perform business valuations that he does not in fact have,
including courses on valuation that he has not successfully
completed. Mr. Shelton's report also suggests that he is a
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