- 171 -
Co. v. Commissioner, 74 T.C. 441, 452 (1980), we may be selective
in the use of any part of such opinion, or reject the opinion in
its entirety, see Parker v. Commissioner, supra at 561. Finally,
because valuation necessarily results in an approximation, the
figure we arrive at need not be directly attributable to 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).
II. Experts and Their Credentials
A. Petitioners’ Expert, John H. Lax
Before filing the estate tax return, petitioners obtained an
appraisal (initial Lax report) of the estate’s corporate and
partnership interests in the True companies as of June 3, 1994,
from the Valuation Services Group of Arthur Andersen LLP (AA),
Houston, Texas. John H. Lax (Mr. Lax), a principal at AA,
participated in the evaluation of the True companies, assisted in
the preparation of the reports, and testified at trial on behalf
of petitioners. Mr. Lax specializes in financial analysis and
appraisal of business enterprises, individual securities, and
various intangible assets. He earned a Senior American Society
of Appraisers designation in 1975 and became a Certified
Management Accountant in 1976.
Petitioners provided a copy of the initial Lax report to the
IRS during the 1993 gift tax return audit, which overlapped with
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