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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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