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Lukens v. Commissioner, 945 F.2d 92, 96 (5th Cir. 1991) (citing
Silverman v. Commissioner, 538 F.2d 927, 933 (2d Cir. 1976),
affg. T.C. Memo. 1974-285). Finally, because valuation is
necessarily an approximation, it is not required that the value
we determine be one as to which there is specific testimony,
provided it is within the range of figures that properly may be
deduced from the evidence. See Silverman v. Commissioner, supra;
Anderson v. Commissioner, 250 F.2d 242, 249 (5th Cir. 1957),
affg. in part and remanding in part T.C. Memo. 1956-178. With
these principles in mind, we consider the experts' opinions.
Petitioner's Expert's Opinion
Petitioner's expert is John R. Gasiorowski (Gasiorowski).
Gasiorowski is the director of Arthur Anderson & Co. Valuation
Services in Northern California, and he has had extensive
experience in valuing businesses. In his report, Gasiorowski
used the market and income methods to value petitioner's Savings
shares.
The market method measures the value of an asset through an
analysis of recent sales or offerings of comparable property. If
comparable publicly traded companies can be found, then the stock
prices for those companies can be used to derive benchmarks, such
as financial ratios, which can be applied to the corresponding
financial measures of the subject company to derive a value for
its stock.
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