- 35 -
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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