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As is customary for valuation issues, the parties rely
extensively on the opinions of their respective experts to
support their differing views about the fair market value of the
gifts of partnership interests. The estate relies on Elliott, a
senior member of the American Society of Appraisers and a
principal in the business valuation firm of Howard Frazier Barker
Elliott, Inc. Respondent relies on Francis X. Burns (Burns), a
candidate member of the American Society of Appraisers and a
principal in the business valuation firm of IPC Group, Inc. Each
expert prepared a report.
We evaluate the opinions of the experts in light of the
demonstrated qualifications of each expert and all other evidence
in the record. See Estate of Davis v. Commissioner, supra at
536. We are not bound by the formulae and opinions proffered by
expert witnesses, especially when they are contrary to our
judgment. Instead, we may reach a determination of value based
on our own examination of the evidence in the record. Where
experts offer contradicting estimates of fair market value, we
decide what weight to give those estimates by examining the
factors used by the experts in arriving at their conclusions.
See id. Moreover, because valuation is necessarily an
approximation, it is not required that the value that we
determine be one as to which there is specific testimony,
provided that it is within the range of figures that properly may
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