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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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