Estate of Etta H. Weinberg - Page 10

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             qualifications of the expert and all other evidence of                   
             value.  See Estate of Newhouse v. Commissioner, supra at                 
             217; Parker v. Commissioner, 86 T.C. 547, 561 (1986).  The               
             Court is not bound by the opinion of any expert witness.                 
             See Estate of Newhouse v. Commissioner, supra at 217;                    
             Estate of Hall v. Commissioner, supra at 338; Parker v.                  
             Commissioner, 86 T.C. at 561.  The Court may adopt an                    
             expert's entire opinion or selectively choose to adopt                   
             some portion of the expert's opinion.  See Parker v.                     
             Commissioner, supra at 562.  Because valuation necessarily               
             results in an approximation, the value at which the 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, 538 F.2d 927, 933              
             (2d Cir. 1976), affg. T.C. Memo. 1974-285.                               

             Petitioners' Expert                                                      
                  Petitioners rely on the expert report of Mr. Robert                 
             M. Siwicki of Howard, Lawson & Co.  Mr. Siwicki is an                    
             accredited senior appraiser with the American Society of                 
             Appraisers and holds a master's degree in finance from the               
             Wharton School.                                                          

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