Estate of George C. Blount, Deceased, Fred B. Aftergut, Executor - Page 58

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          Cir. 1999).  Finally, because valuation necessarily involves 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 properly may be derived from consideration of all the           
          evidence.  Estate of True v. Commissioner, T.C. Memo. 2001-167              
          (citing Silverman v. Commissioner, supra at 933).                           
          C.   BCC’s Value Exclusive of Insurance Proceeds                            
               1.  Experts’ Concluded Value Exclusive of Insurance Proceeds           
               Putting aside their treatment of the insurance proceeds on             
          decedent’s life, Messrs. Fodor and Hitchner determined BCC’s                
          value to be $6 million and $7 million, respectively.  Both used a           
          blend of income- and asset-based approaches.  For their income-             
          based approach, both experts used a capitalization of earnings              
          model, in which they estimated BCC’s net free cashflow capacity             
          for the year following the valuation date, capitalized that                 
          figure to derive capitalized earnings, and then made various, but           
          different, additions to and subtractions from capitalized                   
          earnings.  They relied primarily on BCC’s net asset value for               
          their asset-based valuations.                                               
               Mr. Fodor determined that BCC had an income-based value of             
          $5,803,163 and an asset-based value of $7,928,805.  He weighted             
          the income-based approach at 75 percent and the asset-based                 
          approach at 25 percent to arrive at his $6 million figure.                  

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