- 38 -                                         
          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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