Estate of Mary D. Maggos - Page 29




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          because valuation necessarily results in an approximation, the              
          figure at which this Court arrives 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; Alvary v.           
          United States, 302 F.2d 790, 795 (2d Cir. 1962).                            
          Respondent’s Expert                                                         
               Respondent employed the services of Business Valuation                 
          Services, Inc. (BVS), to value 567 shares of the common stock of            
          PCAB as of May 1, 1987.  David N. Fuller, a principal of BVS,               
          gave testimony at the trial.  Mr. Fuller has an M.B.A. degree in            
          finance from Southern Methodist University, and is an accredited            
          senior appraiser as designated by the American Socy. of                     
          Appraisers and a Chartered Financial Analyst.                               
               The BVS report concluded that the fair market value of 567             
          shares of the common stock of PCAB on May 1, 1987, was                      
          $7,938,000.  This conclusion is based on 100 percent of the                 
          common stock of PCAB having a value of $14 million.  To arrive at           
          this conclusion, BVS prepared several separate analyses.  BVS               
          prepared a discounted cash-flow, a guideline company, a market              
          transaction, and an acquisition analysis.  Each is discussed                
          below.                                                                      










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