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revg. in part T.C. Memo. 1986-318. We are not bound by the
formulae and opinions proffered by expert witnesses, especially
when they are contrary to our judgment. Silverman v.
Commissioner, supra; IT&S of Iowa, Inc. v. Commissioner, 97 T.C.
496, 508 (1991). Instead, we may reach a determination of value
based on our own examination of the evidence in the record.
Lukens v. Commissioner, 945 F.2d 92, 96 (5th Cir. 1991)(citing
Silverman v. Commissioner, supra at 933), affg. Ames v.
Commissioner, T.C. Memo. 1990-87. The persuasiveness of an
expert's opinion depends largely upon the disclosed facts on which
it is based. See Tripp v. Commissioner, 337 F.2d 432, 434 (7th
Cir. 1964), affg. T.C. Memo. 1963-244. Where experts offer
divergent estimates of fair market value, we shall decide what
weight to give those estimates by examining the factors used by
those experts to arrive at their conclusions. Casey v.
Commissioner, 38 T.C. 357, 381 (1962). While we may accept the
opinion of an expert in its entirety, Buffalo Tool & Die
Manufacturing Co. v. Commissioner, 74 T.C. 441, 452 (1980), we may
be selective in the use of any part of such an opinion, Parker v.
Commissioner, supra at 562. We also may reject the opinion of an
expert witness in its entirety. Palmer v. Commissioner, 523 F.2d
1308, 1310 (8th Cir. 1975), affg. 62 T.C. 684 (1974); Parker v.
Commissioner, supra at 562.
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