- 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.Page: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Next
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