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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. 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
values that may properly be arrived at from consideration of all
the evidence. See 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 David N. Fuller, a
principal in the Dallas, Texas, office of Business Valuation
Services, Inc. (BVS). Mr. Fuller has worked in business
valuation since he graduated from Southern Methodist University
in 1989 with an M.B.A. in finance. He was a Manager in the
Valuation Group at Deloitte & Touche from 1989 until 1992, when
he became associated with BVS. Mr. Fuller is an Accredited
Senior Appraiser and Chartered Financial Analyst. Mr. Fuller
valued the estate shares at $8,939,000 ($5,963.25 per share)
using the weighted average value of the estate shares under an
income approach and a market approach, reduced by a marketability
discount of 10 percent.
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