- 18 -
186 (1994), and authorities cited therein. Finally, because
valuation necessarily results in an approximation, the figure at
which we arrive 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).
Petitioners’ Expert’s Reports
Petitioners rely on two reports prepared by Ms. Walker as
the primary evidence in support of their position. Ms. Walker
received a bachelor of arts degree from the University of
Wisconsin at Madison. She is a Chartered Financial Analyst and a
member of the American Society of Appraisers, holding the
Accredited Senior Appraiser (business valuation) designation.
Ms. Walker prepared her first report several years before
trial; a copy of that report was submitted with petitioners’ gift
tax returns for the year in issue.9 Ms. Walker prepared a
revised report shortly before trial, to respond to respondent’s
criticism of Ms. Walker’s failure to include an “income-based”
9 Although Ms. Walker’s original report concluded that the
overall value of the gifts was $211.20 per share, petitioners
reported a 5 percent higher value, $221.75 per share, on their
gift tax returns. Mr. Wall testified that the reason for this
was his accountants’ advice, based on their experience with
respondent’s local personnel, that the lack of marketability and
nonvoting stock discounts determined by Ms. Walker “might better
be a little more conservative”.
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