John T. Talkington and Margaret K. Talkington - Page 9

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               The fair market value of donated property as of a given date           
          is a question of fact to be determined from the entire record.              
          Symington v. Commissioner, 87 T.C. 892, 896 (1986); Zmuda v.                
          Commissioner, 79 T.C. 714, 726 (1982), affd. 731 F.2d 1417 (9th             
          Cir. 1984).  Fair market value reflects the highest and best use            
          of the property on the date of valuation.  Stanley Works & Subs.            
          v. Commissioner, 87 T.C. 389, 400 (1986).  The highest and best             
          use of property is the realistic, objective potential use to                
          which the property can be put.  Id.; see also Olson v. United               
          States, 292 U.S. 246, 255-256 (1934).  The determination of fair            
          market value is not dependent upon whether the property is                  
          actually being put to its highest and best use.  Symington v.               
          Commissioner, supra at 897.  Thus, in determining the reasonable            
          and probable use that supports the highest present value, we                
          focus on the "highest and most profitable use for which the                 
          property is adaptable and needed or likely to be needed in the              
          reasonably near future".  Olson v. United States, supra at 255.             
               In this case, the parties have relied extensively on the               
          testimony of expert witnesses to support their respective views             
          on the fair market value.  Before turning to an analysis of the             
          divergent expert opinions, we note that, as the trier of fact,              
          the Court must weigh the evidence presented by the experts in               
          light of their demonstrated qualifications in addition to all               
          other credible evidence.  Estate of Christ v. Commissioner, 480             





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