Estate of Richard R. Simplot - Page 35




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          Newhouse v. Commissioner, supra at 217; Chiu v. Commissioner, 84            
          T.C. 722, 734 (1985).  Instead, we may reach a decision as to the           
          value of the property based on our own analysis of all the evidence         
          in the record, see Silverman v. Commissioner, 538 F.2d 927, 933 (2d         
          Cir. 1976), affg. T.C. Memo. 1974-285; Hamm v. Commissioner, 325            
          F.2d at 941, using all of one party's expert opinion, see Buffalo           
          Tool & Die Manufacturing Co. v. Commissioner, 74 T.C. 441, 452              
          (1980), or selectively using any portion of such an opinion, see            
          Parker v. Commissioner, 86 T.C. 547, 562 (1986).  We have broad             
          discretion in selecting valuation methods, see Estate of O'Connell          
          v. Commissioner, supra at 251, and in ascertaining the weight to be         
          given the facts in reaching our conclusion because "finding market          
          value is, after all, something for judgment, experience, and                
          reason", Colonial Fabrics, Inc. v. Commissioner, 202 F.2d at 107.           
          Finally, because valuation necessarily results in an approximation,         
          the figure at which we arrive need not be one as to which there is          
          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.                                    
               A.  Valuations of Petitioner's Experts                                 
                    1.  Paul J. Much                                                  
               Petitioner's first expert, Paul J. Much, is senior managing            
          director of Houlihan Lokey Howard & Zukin, an investment banking            
          firm. He valued both the class A voting shares and class B                  
          nonvoting shares at $2,964.10 per share on a nonmarketable                  
          minority-interest basis as of the valuation date.                           

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