BTR Dunlop Holdings, Inc. - Page 16




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          examining the factors they used in arriving at their conclusions.           
          See Casey v. Commissioner, 38 T.C. 357, 381 (1962).  While we may           
          accept an expert opinion in its entirety, Buffalo Tool & Die                
          Manufacturing Co. v. Commissioner, 74 T.C. 441, 452 (1980), 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.  We may also reach a determination of value based on our own           
          examination of the evidence in the record.  See Estate of Davis             
          v. Commissioner, 110 T.C. 530, 538 (1998).  Finally, because                
          valuation necessarily results in an approximation, the figure at            
          which we arrive need not be directly attributable to specific               
          testimony if it is within the range of value that may be properly           
          arrived at from consideration of the evidence.  See Silverman v.            
          Commissioner, 538 F.2d 927, 933 (2d Cir. 1976), affg. T.C. Memo.            
          1974-285.                                                                   
               Respondent relies on the expert report of Alan C. Shapiro              
          (Shapiro), a professor of banking and finance at the University             
          of Southern California, Marshall School of Business, in valuing             
          Schlegel UK and Schlegel GmbH.  Petitioner relies on the expert             
          reports of Lawrence B. Gooch (Gooch) of PricewaterhouseCoopers              
          LLP and Kenneth R. Button (Button) of Economic Consulting                   
          Services, Inc., in valuing Schlegel UK and relies on the expert             
          report of Wilfried Lahmann (Lahmann) of Schitag Ernst & Young in            







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