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any expert opinion. Estate of Davis v. Commissioner, 110 T.C.
530, 538 (1998). Because valuation necessarily involves an
approximation, the figure at which we arrive need not be directly
traceable to specific testimony or a specific expert opinion if
it is within the range of values that may be properly derived
from consideration of all the evidence. Estate of True v.
Commissioner, T.C. Memo. 2001-167 (citing Silverman v.
Commissioner, 538 F.2d 927, 933 (2d Cir. 1976), affg. T.C. Memo.
1974-285).
b. The Estate’s Expert
The estate employed ATI in December of 1999 to prepare a
valuation report for transfers decedent made at yearend.
Decedent’s death, however, converted the Federal gift tax
valuation study into a Federal estate tax valuation study. The
estate’s communications regarding the valuation were solely with
Ron Lint (Mr. Lint), the founder and president of ATI. Mr. Lint
has the designation of accredited senior appraiser from the
American Society of Appraisers (ASA). Mr. Lint testified that he
assigned the valuation project to Jeff Mills (Mr. Mills), a
subordinate at ATI, who also has the designation of accredited
senior appraiser from the ASA. The valuation report was prepared
and signed by Mr. Mills, but Mr. Lint adopted the report as his
own.
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